2024-002 – Indirect Costs (IDC)
Federal Programs – Research and Development Cluster (Assistance Listing No. 98.001 and 93.855)
Federal Agencies - U.S. Agency for International Development and Department of Health and Human Services
Federal Award Year – July 1, 2023 to June 30, 2024
Compliance Requirement – Activities Allowed/Unallowed and Allowable Costs
Criteria Requirement:
Indirect (facilities and administrative(F&A)) costs are those costs that are incurred for common or joint
objectives and, therefore, cannot be identified readily and specifically with a particular sponsored project, an
instructional activity, or any other institutional activity (2 CFR section 200.1).
Per 2 CFR 200, Appendix III, paragraph C.2, indirect costs requires that the negotiated (or submitted) rate(s)
are applied to the appropriate distribution base. Also, as described in 2 CFR section 200.403, costs must be consistently charged as either indirect or direct but may not be double charged or inconsistently charged as
both.
Condition Found:
For four out of twelve samples, the indirect cost recorded was overstated due to miscalculations of IDC due to
an ineffective control over the review and recalculation of indirect costs.
• For three out of the twelve samples, the miscalculations were overstated due to a calculation error in the
year end closing entry. However, the last draw request submitted for FY24 was on September 18, 2024, for
expenses incurred/booked through June 30, 2024; and the indirect costs claimed on this draw request were
calculated accurately, and did not include the overages. Therefore, these samples were not considered to
be compliance findings as EVMS did not seek reimbursement for more than was allowable within the
period of performance. As a result of the deficiency, the error resulted in questioned costs of approximately
$66 on the SEFA.
• For one out of twelve samples, the indirect cost calculation was performed using the incorrect cost base,
resulting in an overstatement of indirect costs of $4,793.92, causing a partially overdrawn amount of
$2,046.42, which resulted in noncompliance and questioned costs on the SEFA.
Cause and Possible Asserted Effect:
The institution’s control to review the indirect cost calculations did not operate consistently to ensure indirect
costs were accurately recorded. Consequently, there were questioned costs and an overdrawn amount in
FY24.
Identification of Questioned Costs:
The questioned costs associated with this finding are $4,859.92.
Sampling:
The sample was not intended to be and was not a statistically valid sample.
Identification of Repeat Finding:
This finding is not a repeat of a finding in the immediately prior year.
Recommendation:
Our recommendation is for management to reinforce and train those individuals in the compliance control
ownership role to ensure controls are operating as designed in order to prevent, or detect and correct
noncompliance on a timely basis. Specifically, strengthening its processes and controls around accuracy of the
review over indirect costs calculation requirements. This will help ensure that controls are functioning as
intended, thereby preventing or promptly identifying and rectifying instances of noncompliance.
Views of Responsible Officials:
Management agrees with the findings and recommendations. Through the merger with Old Dominion
University, additional controls have been adopted around the processes and controls around the accuracy of
the review over indirect cost calculation requirements.
2024-002 – Indirect Costs (IDC)
Federal Programs – Research and Development Cluster (Assistance Listing No. 98.001 and 93.855)
Federal Agencies - U.S. Agency for International Development and Department of Health and Human Services
Federal Award Year – July 1, 2023 to June 30, 2024
Compliance Requirement – Activities Allowed/Unallowed and Allowable Costs
Criteria Requirement:
Indirect (facilities and administrative(F&A)) costs are those costs that are incurred for common or joint
objectives and, therefore, cannot be identified readily and specifically with a particular sponsored project, an
instructional activity, or any other institutional activity (2 CFR section 200.1).
Per 2 CFR 200, Appendix III, paragraph C.2, indirect costs requires that the negotiated (or submitted) rate(s)
are applied to the appropriate distribution base. Also, as described in 2 CFR section 200.403, costs must be consistently charged as either indirect or direct but may not be double charged or inconsistently charged as
both.
Condition Found:
For four out of twelve samples, the indirect cost recorded was overstated due to miscalculations of IDC due to
an ineffective control over the review and recalculation of indirect costs.
• For three out of the twelve samples, the miscalculations were overstated due to a calculation error in the
year end closing entry. However, the last draw request submitted for FY24 was on September 18, 2024, for
expenses incurred/booked through June 30, 2024; and the indirect costs claimed on this draw request were
calculated accurately, and did not include the overages. Therefore, these samples were not considered to
be compliance findings as EVMS did not seek reimbursement for more than was allowable within the
period of performance. As a result of the deficiency, the error resulted in questioned costs of approximately
$66 on the SEFA.
• For one out of twelve samples, the indirect cost calculation was performed using the incorrect cost base,
resulting in an overstatement of indirect costs of $4,793.92, causing a partially overdrawn amount of
$2,046.42, which resulted in noncompliance and questioned costs on the SEFA.
Cause and Possible Asserted Effect:
The institution’s control to review the indirect cost calculations did not operate consistently to ensure indirect
costs were accurately recorded. Consequently, there were questioned costs and an overdrawn amount in
FY24.
Identification of Questioned Costs:
The questioned costs associated with this finding are $4,859.92.
Sampling:
The sample was not intended to be and was not a statistically valid sample.
Identification of Repeat Finding:
This finding is not a repeat of a finding in the immediately prior year.
Recommendation:
Our recommendation is for management to reinforce and train those individuals in the compliance control
ownership role to ensure controls are operating as designed in order to prevent, or detect and correct
noncompliance on a timely basis. Specifically, strengthening its processes and controls around accuracy of the
review over indirect costs calculation requirements. This will help ensure that controls are functioning as
intended, thereby preventing or promptly identifying and rectifying instances of noncompliance.
Views of Responsible Officials:
Management agrees with the findings and recommendations. Through the merger with Old Dominion
University, additional controls have been adopted around the processes and controls around the accuracy of
the review over indirect cost calculation requirements.
2024-002 – Indirect Costs (IDC)
Federal Programs – Research and Development Cluster (Assistance Listing No. 98.001 and 93.855)
Federal Agencies - U.S. Agency for International Development and Department of Health and Human Services
Federal Award Year – July 1, 2023 to June 30, 2024
Compliance Requirement – Activities Allowed/Unallowed and Allowable Costs
Criteria Requirement:
Indirect (facilities and administrative(F&A)) costs are those costs that are incurred for common or joint
objectives and, therefore, cannot be identified readily and specifically with a particular sponsored project, an
instructional activity, or any other institutional activity (2 CFR section 200.1).
Per 2 CFR 200, Appendix III, paragraph C.2, indirect costs requires that the negotiated (or submitted) rate(s)
are applied to the appropriate distribution base. Also, as described in 2 CFR section 200.403, costs must be consistently charged as either indirect or direct but may not be double charged or inconsistently charged as
both.
Condition Found:
For four out of twelve samples, the indirect cost recorded was overstated due to miscalculations of IDC due to
an ineffective control over the review and recalculation of indirect costs.
• For three out of the twelve samples, the miscalculations were overstated due to a calculation error in the
year end closing entry. However, the last draw request submitted for FY24 was on September 18, 2024, for
expenses incurred/booked through June 30, 2024; and the indirect costs claimed on this draw request were
calculated accurately, and did not include the overages. Therefore, these samples were not considered to
be compliance findings as EVMS did not seek reimbursement for more than was allowable within the
period of performance. As a result of the deficiency, the error resulted in questioned costs of approximately
$66 on the SEFA.
• For one out of twelve samples, the indirect cost calculation was performed using the incorrect cost base,
resulting in an overstatement of indirect costs of $4,793.92, causing a partially overdrawn amount of
$2,046.42, which resulted in noncompliance and questioned costs on the SEFA.
Cause and Possible Asserted Effect:
The institution’s control to review the indirect cost calculations did not operate consistently to ensure indirect
costs were accurately recorded. Consequently, there were questioned costs and an overdrawn amount in
FY24.
Identification of Questioned Costs:
The questioned costs associated with this finding are $4,859.92.
Sampling:
The sample was not intended to be and was not a statistically valid sample.
Identification of Repeat Finding:
This finding is not a repeat of a finding in the immediately prior year.
Recommendation:
Our recommendation is for management to reinforce and train those individuals in the compliance control
ownership role to ensure controls are operating as designed in order to prevent, or detect and correct
noncompliance on a timely basis. Specifically, strengthening its processes and controls around accuracy of the
review over indirect costs calculation requirements. This will help ensure that controls are functioning as
intended, thereby preventing or promptly identifying and rectifying instances of noncompliance.
Views of Responsible Officials:
Management agrees with the findings and recommendations. Through the merger with Old Dominion
University, additional controls have been adopted around the processes and controls around the accuracy of
the review over indirect cost calculation requirements.
2024-002 – Indirect Costs (IDC)
Federal Programs – Research and Development Cluster (Assistance Listing No. 98.001 and 93.855)
Federal Agencies - U.S. Agency for International Development and Department of Health and Human Services
Federal Award Year – July 1, 2023 to June 30, 2024
Compliance Requirement – Activities Allowed/Unallowed and Allowable Costs
Criteria Requirement:
Indirect (facilities and administrative(F&A)) costs are those costs that are incurred for common or joint
objectives and, therefore, cannot be identified readily and specifically with a particular sponsored project, an
instructional activity, or any other institutional activity (2 CFR section 200.1).
Per 2 CFR 200, Appendix III, paragraph C.2, indirect costs requires that the negotiated (or submitted) rate(s)
are applied to the appropriate distribution base. Also, as described in 2 CFR section 200.403, costs must be consistently charged as either indirect or direct but may not be double charged or inconsistently charged as
both.
Condition Found:
For four out of twelve samples, the indirect cost recorded was overstated due to miscalculations of IDC due to
an ineffective control over the review and recalculation of indirect costs.
• For three out of the twelve samples, the miscalculations were overstated due to a calculation error in the
year end closing entry. However, the last draw request submitted for FY24 was on September 18, 2024, for
expenses incurred/booked through June 30, 2024; and the indirect costs claimed on this draw request were
calculated accurately, and did not include the overages. Therefore, these samples were not considered to
be compliance findings as EVMS did not seek reimbursement for more than was allowable within the
period of performance. As a result of the deficiency, the error resulted in questioned costs of approximately
$66 on the SEFA.
• For one out of twelve samples, the indirect cost calculation was performed using the incorrect cost base,
resulting in an overstatement of indirect costs of $4,793.92, causing a partially overdrawn amount of
$2,046.42, which resulted in noncompliance and questioned costs on the SEFA.
Cause and Possible Asserted Effect:
The institution’s control to review the indirect cost calculations did not operate consistently to ensure indirect
costs were accurately recorded. Consequently, there were questioned costs and an overdrawn amount in
FY24.
Identification of Questioned Costs:
The questioned costs associated with this finding are $4,859.92.
Sampling:
The sample was not intended to be and was not a statistically valid sample.
Identification of Repeat Finding:
This finding is not a repeat of a finding in the immediately prior year.
Recommendation:
Our recommendation is for management to reinforce and train those individuals in the compliance control
ownership role to ensure controls are operating as designed in order to prevent, or detect and correct
noncompliance on a timely basis. Specifically, strengthening its processes and controls around accuracy of the
review over indirect costs calculation requirements. This will help ensure that controls are functioning as
intended, thereby preventing or promptly identifying and rectifying instances of noncompliance.
Views of Responsible Officials:
Management agrees with the findings and recommendations. Through the merger with Old Dominion
University, additional controls have been adopted around the processes and controls around the accuracy of
the review over indirect cost calculation requirements.
2024-003 – Cash Management Approval
Federal Programs – Research and Development Cluster (Assistance Listing No. 98.001)
Federal Agencies - U.S. Agency for International Development
Federal Award Year – July 1, 2023 to June 30, 2024
Compliance Requirement – Cash Management
Criteria Requirement:
Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or
pass-through entity and disbursement by the non-federal entity for direct program or project costs and the
proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or
issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)).
The reimbursement payment method is the preferred payment method if (a) the non-federal entity cannot the
meet the requirements in 2 CFR section 200.305(b)(1) for advance payment, (b) the federal awarding agency
sets a specific condition for use of the reimbursement or (c) if requested by the non-federal entity (2 CFR
sections 200.305(b)(3) and 200.208). The reimbursement payment method also may be used on a federal
award for construction or for other construction activity as specified in 2 CFR section 200.305(b)(3).
Condition Found:
For two out of thirty-one samples, the institution did not maintain appropriate documentation to evidence the
approval of the drawdown request. This resulted in an ineffective control over the review and approval of cash
drawdowns.
Cause and Possible Asserted Effect:
The grants department had turnover in the current year, which resulted in inconsistent documentation of
approvals. Therefore, the institution’s control to review and approve cash drawdowns did not operate
consistently to ensure requests for reimbursement were properly approved and evidence of the review was
maintained.
Identification of Questioned Costs:
There are no questioned costs associated with this finding.
Sampling:
The sample was not intended to be and was not a statistically valid sample.
Identification of Repeat Finding:
This finding is not a repeat of a finding in the immediately prior year
Recommendation:
Our recommendation is for management to reinforce and train those individuals in the compliance control
ownership role to ensure controls are operating as designed in order to prevent, or detect and correct noncompliance on a timely basis. Specifically, strengthening its processes and documentation requirements
around the review and approval of cash drawdown requests. This will help ensure that controls are functioning
as intended, thereby preventing or promptly identifying and rectifying instances of noncompliance.
Views of Responsible Officials:
Management agrees with the findings and recommendations. Through the merger with Old Dominion
University, additional controls have been adopted around the processes and controls around the accuracy of
the review and approval of cash drawdown requests.
2024-003 – Cash Management Approval
Federal Programs – Research and Development Cluster (Assistance Listing No. 98.001)
Federal Agencies - U.S. Agency for International Development
Federal Award Year – July 1, 2023 to June 30, 2024
Compliance Requirement – Cash Management
Criteria Requirement:
Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or
pass-through entity and disbursement by the non-federal entity for direct program or project costs and the
proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or
issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)).
The reimbursement payment method is the preferred payment method if (a) the non-federal entity cannot the
meet the requirements in 2 CFR section 200.305(b)(1) for advance payment, (b) the federal awarding agency
sets a specific condition for use of the reimbursement or (c) if requested by the non-federal entity (2 CFR
sections 200.305(b)(3) and 200.208). The reimbursement payment method also may be used on a federal
award for construction or for other construction activity as specified in 2 CFR section 200.305(b)(3).
Condition Found:
For two out of thirty-one samples, the institution did not maintain appropriate documentation to evidence the
approval of the drawdown request. This resulted in an ineffective control over the review and approval of cash
drawdowns.
Cause and Possible Asserted Effect:
The grants department had turnover in the current year, which resulted in inconsistent documentation of
approvals. Therefore, the institution’s control to review and approve cash drawdowns did not operate
consistently to ensure requests for reimbursement were properly approved and evidence of the review was
maintained.
Identification of Questioned Costs:
There are no questioned costs associated with this finding.
Sampling:
The sample was not intended to be and was not a statistically valid sample.
Identification of Repeat Finding:
This finding is not a repeat of a finding in the immediately prior year
Recommendation:
Our recommendation is for management to reinforce and train those individuals in the compliance control
ownership role to ensure controls are operating as designed in order to prevent, or detect and correct noncompliance on a timely basis. Specifically, strengthening its processes and documentation requirements
around the review and approval of cash drawdown requests. This will help ensure that controls are functioning
as intended, thereby preventing or promptly identifying and rectifying instances of noncompliance.
Views of Responsible Officials:
Management agrees with the findings and recommendations. Through the merger with Old Dominion
University, additional controls have been adopted around the processes and controls around the accuracy of
the review and approval of cash drawdown requests.
2024-003 – Cash Management Approval
Federal Programs – Research and Development Cluster (Assistance Listing No. 98.001)
Federal Agencies - U.S. Agency for International Development
Federal Award Year – July 1, 2023 to June 30, 2024
Compliance Requirement – Cash Management
Criteria Requirement:
Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or
pass-through entity and disbursement by the non-federal entity for direct program or project costs and the
proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or
issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)).
The reimbursement payment method is the preferred payment method if (a) the non-federal entity cannot the
meet the requirements in 2 CFR section 200.305(b)(1) for advance payment, (b) the federal awarding agency
sets a specific condition for use of the reimbursement or (c) if requested by the non-federal entity (2 CFR
sections 200.305(b)(3) and 200.208). The reimbursement payment method also may be used on a federal
award for construction or for other construction activity as specified in 2 CFR section 200.305(b)(3).
Condition Found:
For two out of thirty-one samples, the institution did not maintain appropriate documentation to evidence the
approval of the drawdown request. This resulted in an ineffective control over the review and approval of cash
drawdowns.
Cause and Possible Asserted Effect:
The grants department had turnover in the current year, which resulted in inconsistent documentation of
approvals. Therefore, the institution’s control to review and approve cash drawdowns did not operate
consistently to ensure requests for reimbursement were properly approved and evidence of the review was
maintained.
Identification of Questioned Costs:
There are no questioned costs associated with this finding.
Sampling:
The sample was not intended to be and was not a statistically valid sample.
Identification of Repeat Finding:
This finding is not a repeat of a finding in the immediately prior year
Recommendation:
Our recommendation is for management to reinforce and train those individuals in the compliance control
ownership role to ensure controls are operating as designed in order to prevent, or detect and correct noncompliance on a timely basis. Specifically, strengthening its processes and documentation requirements
around the review and approval of cash drawdown requests. This will help ensure that controls are functioning
as intended, thereby preventing or promptly identifying and rectifying instances of noncompliance.
Views of Responsible Officials:
Management agrees with the findings and recommendations. Through the merger with Old Dominion
University, additional controls have been adopted around the processes and controls around the accuracy of
the review and approval of cash drawdown requests.
2024-002 – Indirect Costs (IDC)
Federal Programs – Research and Development Cluster (Assistance Listing No. 98.001 and 93.855)
Federal Agencies - U.S. Agency for International Development and Department of Health and Human Services
Federal Award Year – July 1, 2023 to June 30, 2024
Compliance Requirement – Activities Allowed/Unallowed and Allowable Costs
Criteria Requirement:
Indirect (facilities and administrative(F&A)) costs are those costs that are incurred for common or joint
objectives and, therefore, cannot be identified readily and specifically with a particular sponsored project, an
instructional activity, or any other institutional activity (2 CFR section 200.1).
Per 2 CFR 200, Appendix III, paragraph C.2, indirect costs requires that the negotiated (or submitted) rate(s)
are applied to the appropriate distribution base. Also, as described in 2 CFR section 200.403, costs must be consistently charged as either indirect or direct but may not be double charged or inconsistently charged as
both.
Condition Found:
For four out of twelve samples, the indirect cost recorded was overstated due to miscalculations of IDC due to
an ineffective control over the review and recalculation of indirect costs.
• For three out of the twelve samples, the miscalculations were overstated due to a calculation error in the
year end closing entry. However, the last draw request submitted for FY24 was on September 18, 2024, for
expenses incurred/booked through June 30, 2024; and the indirect costs claimed on this draw request were
calculated accurately, and did not include the overages. Therefore, these samples were not considered to
be compliance findings as EVMS did not seek reimbursement for more than was allowable within the
period of performance. As a result of the deficiency, the error resulted in questioned costs of approximately
$66 on the SEFA.
• For one out of twelve samples, the indirect cost calculation was performed using the incorrect cost base,
resulting in an overstatement of indirect costs of $4,793.92, causing a partially overdrawn amount of
$2,046.42, which resulted in noncompliance and questioned costs on the SEFA.
Cause and Possible Asserted Effect:
The institution’s control to review the indirect cost calculations did not operate consistently to ensure indirect
costs were accurately recorded. Consequently, there were questioned costs and an overdrawn amount in
FY24.
Identification of Questioned Costs:
The questioned costs associated with this finding are $4,859.92.
Sampling:
The sample was not intended to be and was not a statistically valid sample.
Identification of Repeat Finding:
This finding is not a repeat of a finding in the immediately prior year.
Recommendation:
Our recommendation is for management to reinforce and train those individuals in the compliance control
ownership role to ensure controls are operating as designed in order to prevent, or detect and correct
noncompliance on a timely basis. Specifically, strengthening its processes and controls around accuracy of the
review over indirect costs calculation requirements. This will help ensure that controls are functioning as
intended, thereby preventing or promptly identifying and rectifying instances of noncompliance.
Views of Responsible Officials:
Management agrees with the findings and recommendations. Through the merger with Old Dominion
University, additional controls have been adopted around the processes and controls around the accuracy of
the review over indirect cost calculation requirements.
2024-002 – Indirect Costs (IDC)
Federal Programs – Research and Development Cluster (Assistance Listing No. 98.001 and 93.855)
Federal Agencies - U.S. Agency for International Development and Department of Health and Human Services
Federal Award Year – July 1, 2023 to June 30, 2024
Compliance Requirement – Activities Allowed/Unallowed and Allowable Costs
Criteria Requirement:
Indirect (facilities and administrative(F&A)) costs are those costs that are incurred for common or joint
objectives and, therefore, cannot be identified readily and specifically with a particular sponsored project, an
instructional activity, or any other institutional activity (2 CFR section 200.1).
Per 2 CFR 200, Appendix III, paragraph C.2, indirect costs requires that the negotiated (or submitted) rate(s)
are applied to the appropriate distribution base. Also, as described in 2 CFR section 200.403, costs must be consistently charged as either indirect or direct but may not be double charged or inconsistently charged as
both.
Condition Found:
For four out of twelve samples, the indirect cost recorded was overstated due to miscalculations of IDC due to
an ineffective control over the review and recalculation of indirect costs.
• For three out of the twelve samples, the miscalculations were overstated due to a calculation error in the
year end closing entry. However, the last draw request submitted for FY24 was on September 18, 2024, for
expenses incurred/booked through June 30, 2024; and the indirect costs claimed on this draw request were
calculated accurately, and did not include the overages. Therefore, these samples were not considered to
be compliance findings as EVMS did not seek reimbursement for more than was allowable within the
period of performance. As a result of the deficiency, the error resulted in questioned costs of approximately
$66 on the SEFA.
• For one out of twelve samples, the indirect cost calculation was performed using the incorrect cost base,
resulting in an overstatement of indirect costs of $4,793.92, causing a partially overdrawn amount of
$2,046.42, which resulted in noncompliance and questioned costs on the SEFA.
Cause and Possible Asserted Effect:
The institution’s control to review the indirect cost calculations did not operate consistently to ensure indirect
costs were accurately recorded. Consequently, there were questioned costs and an overdrawn amount in
FY24.
Identification of Questioned Costs:
The questioned costs associated with this finding are $4,859.92.
Sampling:
The sample was not intended to be and was not a statistically valid sample.
Identification of Repeat Finding:
This finding is not a repeat of a finding in the immediately prior year.
Recommendation:
Our recommendation is for management to reinforce and train those individuals in the compliance control
ownership role to ensure controls are operating as designed in order to prevent, or detect and correct
noncompliance on a timely basis. Specifically, strengthening its processes and controls around accuracy of the
review over indirect costs calculation requirements. This will help ensure that controls are functioning as
intended, thereby preventing or promptly identifying and rectifying instances of noncompliance.
Views of Responsible Officials:
Management agrees with the findings and recommendations. Through the merger with Old Dominion
University, additional controls have been adopted around the processes and controls around the accuracy of
the review over indirect cost calculation requirements.
2024-002 – Indirect Costs (IDC)
Federal Programs – Research and Development Cluster (Assistance Listing No. 98.001 and 93.855)
Federal Agencies - U.S. Agency for International Development and Department of Health and Human Services
Federal Award Year – July 1, 2023 to June 30, 2024
Compliance Requirement – Activities Allowed/Unallowed and Allowable Costs
Criteria Requirement:
Indirect (facilities and administrative(F&A)) costs are those costs that are incurred for common or joint
objectives and, therefore, cannot be identified readily and specifically with a particular sponsored project, an
instructional activity, or any other institutional activity (2 CFR section 200.1).
Per 2 CFR 200, Appendix III, paragraph C.2, indirect costs requires that the negotiated (or submitted) rate(s)
are applied to the appropriate distribution base. Also, as described in 2 CFR section 200.403, costs must be consistently charged as either indirect or direct but may not be double charged or inconsistently charged as
both.
Condition Found:
For four out of twelve samples, the indirect cost recorded was overstated due to miscalculations of IDC due to
an ineffective control over the review and recalculation of indirect costs.
• For three out of the twelve samples, the miscalculations were overstated due to a calculation error in the
year end closing entry. However, the last draw request submitted for FY24 was on September 18, 2024, for
expenses incurred/booked through June 30, 2024; and the indirect costs claimed on this draw request were
calculated accurately, and did not include the overages. Therefore, these samples were not considered to
be compliance findings as EVMS did not seek reimbursement for more than was allowable within the
period of performance. As a result of the deficiency, the error resulted in questioned costs of approximately
$66 on the SEFA.
• For one out of twelve samples, the indirect cost calculation was performed using the incorrect cost base,
resulting in an overstatement of indirect costs of $4,793.92, causing a partially overdrawn amount of
$2,046.42, which resulted in noncompliance and questioned costs on the SEFA.
Cause and Possible Asserted Effect:
The institution’s control to review the indirect cost calculations did not operate consistently to ensure indirect
costs were accurately recorded. Consequently, there were questioned costs and an overdrawn amount in
FY24.
Identification of Questioned Costs:
The questioned costs associated with this finding are $4,859.92.
Sampling:
The sample was not intended to be and was not a statistically valid sample.
Identification of Repeat Finding:
This finding is not a repeat of a finding in the immediately prior year.
Recommendation:
Our recommendation is for management to reinforce and train those individuals in the compliance control
ownership role to ensure controls are operating as designed in order to prevent, or detect and correct
noncompliance on a timely basis. Specifically, strengthening its processes and controls around accuracy of the
review over indirect costs calculation requirements. This will help ensure that controls are functioning as
intended, thereby preventing or promptly identifying and rectifying instances of noncompliance.
Views of Responsible Officials:
Management agrees with the findings and recommendations. Through the merger with Old Dominion
University, additional controls have been adopted around the processes and controls around the accuracy of
the review over indirect cost calculation requirements.
2024-002 – Indirect Costs (IDC)
Federal Programs – Research and Development Cluster (Assistance Listing No. 98.001 and 93.855)
Federal Agencies - U.S. Agency for International Development and Department of Health and Human Services
Federal Award Year – July 1, 2023 to June 30, 2024
Compliance Requirement – Activities Allowed/Unallowed and Allowable Costs
Criteria Requirement:
Indirect (facilities and administrative(F&A)) costs are those costs that are incurred for common or joint
objectives and, therefore, cannot be identified readily and specifically with a particular sponsored project, an
instructional activity, or any other institutional activity (2 CFR section 200.1).
Per 2 CFR 200, Appendix III, paragraph C.2, indirect costs requires that the negotiated (or submitted) rate(s)
are applied to the appropriate distribution base. Also, as described in 2 CFR section 200.403, costs must be consistently charged as either indirect or direct but may not be double charged or inconsistently charged as
both.
Condition Found:
For four out of twelve samples, the indirect cost recorded was overstated due to miscalculations of IDC due to
an ineffective control over the review and recalculation of indirect costs.
• For three out of the twelve samples, the miscalculations were overstated due to a calculation error in the
year end closing entry. However, the last draw request submitted for FY24 was on September 18, 2024, for
expenses incurred/booked through June 30, 2024; and the indirect costs claimed on this draw request were
calculated accurately, and did not include the overages. Therefore, these samples were not considered to
be compliance findings as EVMS did not seek reimbursement for more than was allowable within the
period of performance. As a result of the deficiency, the error resulted in questioned costs of approximately
$66 on the SEFA.
• For one out of twelve samples, the indirect cost calculation was performed using the incorrect cost base,
resulting in an overstatement of indirect costs of $4,793.92, causing a partially overdrawn amount of
$2,046.42, which resulted in noncompliance and questioned costs on the SEFA.
Cause and Possible Asserted Effect:
The institution’s control to review the indirect cost calculations did not operate consistently to ensure indirect
costs were accurately recorded. Consequently, there were questioned costs and an overdrawn amount in
FY24.
Identification of Questioned Costs:
The questioned costs associated with this finding are $4,859.92.
Sampling:
The sample was not intended to be and was not a statistically valid sample.
Identification of Repeat Finding:
This finding is not a repeat of a finding in the immediately prior year.
Recommendation:
Our recommendation is for management to reinforce and train those individuals in the compliance control
ownership role to ensure controls are operating as designed in order to prevent, or detect and correct
noncompliance on a timely basis. Specifically, strengthening its processes and controls around accuracy of the
review over indirect costs calculation requirements. This will help ensure that controls are functioning as
intended, thereby preventing or promptly identifying and rectifying instances of noncompliance.
Views of Responsible Officials:
Management agrees with the findings and recommendations. Through the merger with Old Dominion
University, additional controls have been adopted around the processes and controls around the accuracy of
the review over indirect cost calculation requirements.
2024-003 – Cash Management Approval
Federal Programs – Research and Development Cluster (Assistance Listing No. 98.001)
Federal Agencies - U.S. Agency for International Development
Federal Award Year – July 1, 2023 to June 30, 2024
Compliance Requirement – Cash Management
Criteria Requirement:
Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or
pass-through entity and disbursement by the non-federal entity for direct program or project costs and the
proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or
issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)).
The reimbursement payment method is the preferred payment method if (a) the non-federal entity cannot the
meet the requirements in 2 CFR section 200.305(b)(1) for advance payment, (b) the federal awarding agency
sets a specific condition for use of the reimbursement or (c) if requested by the non-federal entity (2 CFR
sections 200.305(b)(3) and 200.208). The reimbursement payment method also may be used on a federal
award for construction or for other construction activity as specified in 2 CFR section 200.305(b)(3).
Condition Found:
For two out of thirty-one samples, the institution did not maintain appropriate documentation to evidence the
approval of the drawdown request. This resulted in an ineffective control over the review and approval of cash
drawdowns.
Cause and Possible Asserted Effect:
The grants department had turnover in the current year, which resulted in inconsistent documentation of
approvals. Therefore, the institution’s control to review and approve cash drawdowns did not operate
consistently to ensure requests for reimbursement were properly approved and evidence of the review was
maintained.
Identification of Questioned Costs:
There are no questioned costs associated with this finding.
Sampling:
The sample was not intended to be and was not a statistically valid sample.
Identification of Repeat Finding:
This finding is not a repeat of a finding in the immediately prior year
Recommendation:
Our recommendation is for management to reinforce and train those individuals in the compliance control
ownership role to ensure controls are operating as designed in order to prevent, or detect and correct noncompliance on a timely basis. Specifically, strengthening its processes and documentation requirements
around the review and approval of cash drawdown requests. This will help ensure that controls are functioning
as intended, thereby preventing or promptly identifying and rectifying instances of noncompliance.
Views of Responsible Officials:
Management agrees with the findings and recommendations. Through the merger with Old Dominion
University, additional controls have been adopted around the processes and controls around the accuracy of
the review and approval of cash drawdown requests.
2024-003 – Cash Management Approval
Federal Programs – Research and Development Cluster (Assistance Listing No. 98.001)
Federal Agencies - U.S. Agency for International Development
Federal Award Year – July 1, 2023 to June 30, 2024
Compliance Requirement – Cash Management
Criteria Requirement:
Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or
pass-through entity and disbursement by the non-federal entity for direct program or project costs and the
proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or
issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)).
The reimbursement payment method is the preferred payment method if (a) the non-federal entity cannot the
meet the requirements in 2 CFR section 200.305(b)(1) for advance payment, (b) the federal awarding agency
sets a specific condition for use of the reimbursement or (c) if requested by the non-federal entity (2 CFR
sections 200.305(b)(3) and 200.208). The reimbursement payment method also may be used on a federal
award for construction or for other construction activity as specified in 2 CFR section 200.305(b)(3).
Condition Found:
For two out of thirty-one samples, the institution did not maintain appropriate documentation to evidence the
approval of the drawdown request. This resulted in an ineffective control over the review and approval of cash
drawdowns.
Cause and Possible Asserted Effect:
The grants department had turnover in the current year, which resulted in inconsistent documentation of
approvals. Therefore, the institution’s control to review and approve cash drawdowns did not operate
consistently to ensure requests for reimbursement were properly approved and evidence of the review was
maintained.
Identification of Questioned Costs:
There are no questioned costs associated with this finding.
Sampling:
The sample was not intended to be and was not a statistically valid sample.
Identification of Repeat Finding:
This finding is not a repeat of a finding in the immediately prior year
Recommendation:
Our recommendation is for management to reinforce and train those individuals in the compliance control
ownership role to ensure controls are operating as designed in order to prevent, or detect and correct noncompliance on a timely basis. Specifically, strengthening its processes and documentation requirements
around the review and approval of cash drawdown requests. This will help ensure that controls are functioning
as intended, thereby preventing or promptly identifying and rectifying instances of noncompliance.
Views of Responsible Officials:
Management agrees with the findings and recommendations. Through the merger with Old Dominion
University, additional controls have been adopted around the processes and controls around the accuracy of
the review and approval of cash drawdown requests.
2024-003 – Cash Management Approval
Federal Programs – Research and Development Cluster (Assistance Listing No. 98.001)
Federal Agencies - U.S. Agency for International Development
Federal Award Year – July 1, 2023 to June 30, 2024
Compliance Requirement – Cash Management
Criteria Requirement:
Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or
pass-through entity and disbursement by the non-federal entity for direct program or project costs and the
proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or
issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)).
The reimbursement payment method is the preferred payment method if (a) the non-federal entity cannot the
meet the requirements in 2 CFR section 200.305(b)(1) for advance payment, (b) the federal awarding agency
sets a specific condition for use of the reimbursement or (c) if requested by the non-federal entity (2 CFR
sections 200.305(b)(3) and 200.208). The reimbursement payment method also may be used on a federal
award for construction or for other construction activity as specified in 2 CFR section 200.305(b)(3).
Condition Found:
For two out of thirty-one samples, the institution did not maintain appropriate documentation to evidence the
approval of the drawdown request. This resulted in an ineffective control over the review and approval of cash
drawdowns.
Cause and Possible Asserted Effect:
The grants department had turnover in the current year, which resulted in inconsistent documentation of
approvals. Therefore, the institution’s control to review and approve cash drawdowns did not operate
consistently to ensure requests for reimbursement were properly approved and evidence of the review was
maintained.
Identification of Questioned Costs:
There are no questioned costs associated with this finding.
Sampling:
The sample was not intended to be and was not a statistically valid sample.
Identification of Repeat Finding:
This finding is not a repeat of a finding in the immediately prior year
Recommendation:
Our recommendation is for management to reinforce and train those individuals in the compliance control
ownership role to ensure controls are operating as designed in order to prevent, or detect and correct noncompliance on a timely basis. Specifically, strengthening its processes and documentation requirements
around the review and approval of cash drawdown requests. This will help ensure that controls are functioning
as intended, thereby preventing or promptly identifying and rectifying instances of noncompliance.
Views of Responsible Officials:
Management agrees with the findings and recommendations. Through the merger with Old Dominion
University, additional controls have been adopted around the processes and controls around the accuracy of
the review and approval of cash drawdown requests.