Federal agency name: U.S. National Science Foundation and U.S. Department of Agriculture
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure, Integrative Activities & Forestry Research
AL No.: 47.050, 47.070, 47.079, 47.080, 47.083 & 10.652
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022), OIA-1937099 (09/01/2020
– 08/31/2021) & 19-DG11330140-083 (09/26/2019 – 09/30/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-002 ACCURACY AND COMPLETENESS OF SCHEDULE OF EXPENDITURES OF
FEDERAL AWARDS (“SEFA”)
Material Weakness
Criteria
CUAHSI is required to prepare a SEFA in accordance with the prescribed guidelines of the
Uniform Guidance (“UG”). In addition, 2 CFR Section 200.512(a) of the Uniform Guidance
requires the reporting package and Data Collection Form (“DCF”) to be submitted to the Federal
Audit Clearinghouse the earlier of 30 calendar days after the reports are received from the
auditor or nine months after CUAHSI’s year end.
Condition
CUAHSI provided two different versions of the SEFA to the auditor during the audit process.
Additionally, due to the delay in financial close of CUAHSI’s books and records, a federal single
audit for the year ended December 31, 2021 was not performed in a timely manner and the DCF
was not submitted by its due date of September 30, 2022. The inaccurate reporting of grants and
related activity in the SEFA can lead to improper identification of major programs causing
inadequate testing by the auditor as required by UG. As a result of the audit procedures
performed and proposed adjustments to CUAHSI’s preliminary SEFA by the audit, management
was able to make the required changes.
Cause & Context
Due personnel and staffing issues, CUAHSI was not able to complete the financial close process
in a timely manner which led to the changes in qualified expenditures and delay in the financial
statement and the federal single audit being completed.
Effect
Failure to comply with federal regulations and reporting requirements exposes CUAHSI to
potential legal and regulatory consequences, including the risk of future funding loss and
financial penalties.
Questioned Costs
None
Prior Year Audit Finding
Yes - previously reported as MW2020-002.
Recommendation
To address the identified deficiencies and improve controls over the preparation of the SEFA, the
auditor recommends the development and documentation of procedures for tracking federal
awards and related disbursements to subrecipients.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation and U.S. Department of Agriculture
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure, Integrative Activities & Forestry Research
AL No.: 47.050, 47.070, 47.079, 47.080, 47.083 & 10.652
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022), OIA-1937099 (09/01/2020
– 08/31/2021) & 19-DG11330140-083 (09/26/2019 – 09/30/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-004 REPORTING - DCF
Material Weakness
Criteria
2 CFR Section 200.512(a) requires the reporting package and DCF to be submitted to the Federal
Audit Clearinghouse the earlier of thirty calendar days after the reports are received from the
auditor or nine months after the end of the audit period.
Condition
Due to the delay in financial close of CUAHSI’s books and records, a federal single audit for
fiscal year 2021 was not performed in a timely manner and the DCF was not submitted by its due
date of September 30, 2022. The UG requires the reporting package and DCF to be submitted to
the Federal Audit Clearinghouse the earlier of 30 calendar days after the reports are received
from the auditor (April 2, 2025) or nine months after CUAHSI’s year end (September 30, 2022).
Cause & Context
CUAHSI did not have effective controls in place to allow for a timely year-end closing. This
caused significant auditor delays which resulted in CUAHSI’s inability to meet the filing
requirements under the UG.
Effect
CUAHSI is not in compliance with 2 CFR Part 200, Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-004.
Recommendation
Management should implement policies to ensure timely financial reporting and ensure the
timely completion of an audit.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-005 SUBRECIPIENT MONITORING
Material Weakness
Criteria
The regulations are documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and
.501(h); (Requirements for Pass-Through Entities). The criteria for monitoring subrecipients of
federal awards should be following federal regulations, the terms of the federal contract, and any
additional requirements specified by the auditee's policies and procedures. Specifically, the
monitoring criteria should include, but not be limited to, the following:
• Subrecipient Risk Assessment
• Financial Monitoring
• Compliance Monitoring
• Reporting and Documentation
Condition
The auditee failed to comply with federal regulations requiring the monitoring of subrecipients
for federal awards on a timely basis. Recipients of federal awards are responsible for monitoring
the activities of subrecipients to ensure that they comply with applicable laws, regulations, and
the terms and conditions of the federal award. CUAHSI did not complete the monitoring of its
2021 subrecipients until 2024. During the year ended December 31, 2021, CUAHSI had
$128,472 in amounts paid to subrecipients. Based on our testing of amounts paid to
subrecipients, no amounts were identified as unallowable.
Cause & Context
CUAHSI had a policy and procedure manual in place which outlined the steps for monitoring.
There was no audit evidence of CUAHSI following the policy and monitoring that the
subrecipient was using the funding as prescribed during the year ended December 31, 2021.
Effect
CUAHSI’s lack of monitoring creates a significant risk of the possible misuse or improper use of
funds.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-005.
Recommendation
The auditor recommends that management review the requirements documented in 31 USC
7502(f)(2), 2 CFR sections 200.330, .331, and .501(h);(Requirements for Pass-Through Entities)
and develops and implements procedures to adhere to such requirements.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
Material Weakness
MW2021-006 CASH MANAGEMENT
Criteria
2 CFR Part 200 states that entities expending federal grants must establish and maintain effective
internal control over the federal award that provides reasonable assurance that the non-federal
entity is managing the federal award in compliance with federal statues, regulations, and the
terms and conditions of the Federal award. To comply with 2 CFR Part 200, CUAHSI was
required to submit monthly invoices for the funds received under the federal contract. These
invoices will serve as a record of the services or goods provided during the specified period and
will facilitate accurate tracking and reporting of the funds. In addition to the invoice, any
supporting documentation, such as timesheets, should be maintained with the invoices. The cash
management process should also be adjusted for the receipt of program income.
These documents validate the services provided and ensure transparency and auditability of the
invoiced amount. These amounts should be able to be traced to the general ledger in conjunction
with the time in which they are billed.
Condition
The cash management process requires that cash draws be reviewed and approved to ensure the
propriety of draw reimbursement requests. Management was unable to provide the auditor
evidence documenting approval of the drawdowns for the year ended December 31, 2021.
Cause & Context
CUAHSI had no fiscal management team during the year ended December 31, 2021 to ensure
compliance with proper policies and procedures. The books and records for the year ended
December 31, 2021 were recreated by the current management team during 2024 to 2025.
Effect
Grant awards and reimbursements may not be recorded correctly and there is a higher risk of
error or misappropriation of assets.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-006.
Recommendation
The auditor recommends CUAHSI develop and implement controls to ensure an adequate review
process is in place for review of reimbursement requests submitted to granting agencies to ensure
consistent reporting.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-007 PROCUREMENT, SUSPENSION AND DEBARMENT
Material Weakness
Criteria
The requirements for this compliance requirement are contained in 2 CFR sections 200.317-
200.326; 48 CFR parts 03, 15, 44, and the clauses at 48 CRF sections 52.244-2, 52.244-5,
52.203-13, 52.203-16 and 52.215-12; agency FAR supplements; 2 CFR part 180; OMB M-18-
18; and the terms and conditions of the federal award. There is a requirement to verify that
contractors in covered transactions or any of its vendors are not federally debarred, suspended, or
excluded.
A covered transaction is a nonprocurement or procurement transaction in excess of $25,000 that
is subject to the prohibitions noted in 2 CFR part 180. The covered transaction may be at the
primary tier, between a federal agency and a person or a lower tier between a participant in a
covered transaction and another person.
Condition
During the completion of the audit, the auditor noted that CUAHSI failed to maintain and
provide the proper records and support to document their review of vendor files for covered
transactions. Such failure led to non-compliance with the procurement, suspension and
debarment policies in accordance with the UG for the year ended December 31, 2021. CUAHSI
did not complete the verification of its 2021 vendors until 2024. Based on our testing, no
contractors in covered transactions were deemed to be federally debarred, suspended or
excluded. Material Weakness
Cause & Context
CUAHSI has a policy in place to meet the procurement requirements but there was no evidence
of compliance with that policy.
Effect
As a result of noncompliance, there could be possible repayment of funds, loss of reputation and
possible suspension or debarment.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-007.
Recommendation
It is recommended that CUAHSI strive to prioritize compliance. CUAHSI should ensure that, to
the extent practicable, the use of a competitive procurement process in compliance with 2 CFR
section 200/317.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-008 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF
EXPENDITURES
Material Weakness
Criteria
CFR § 200.305 Cash management: This section of the CFR outlines the requirements for the
management of cash drawdowns and disbursements of federal funds. Federal funds should be
disbursed in a timely manner for allowable costs that have been incurred. Cash advances must
meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National
Science Foundation.
Condition
CUAHSI did not meet the conditions specified in Chapter VIII.C.3 of the grant agreement with
the National Science Foundation which details the requirements for advance fundings. During
2021, CUAHSI had advance drawdowns totaling $1,172,645 from the NSF. Of this amount,
CUAHSI incurred $1,049,681 in eligible expenses for the year ended December 31, 2021. This
resulted in $122,964 in excess federal advances as of year-end. The draw downs in excess of
revenue recognized during the year ended December 31, 2021 are reported as part of deferred
revenue in the accompanying Statement of Financial Position.
Cause & Context
CUAHSI initiated advance drawdowns without following the guidelines set forth by Chapter
VIII.C.3 of the grant agreement.
Effect
Drawing down funds in advance of incurring eligible expenses could lead to non-compliance
with federal regulations, such as those outlined in 2 CFR § 200.305. This may result in the need
to repay the funds, potential financial penalties, or disqualification from future federal funding.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-008.
Recommendation
The auditor recommends that CUAHSI develops and implements controls over policies
consistent with 2 CFR 200.35.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-009 PROGRAM INCOME
Material Weakness
Criteria
Pursuant to 2 CFR 200 for award objectives and the regulations at 2 CFR 200.307, program
income is defined as “Gross income earned by the recipient that is directly generated by a
supported activity or earned as a result of the federal award during the period of performance” by
2 CFR Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements
for Federal Awards. Program income reporting is due forty five (45) days after the end of the
federal fiscal year. NSF requires that all cumulative program income is reported for all open
grants and agreements in the current year.
Condition
Program income consists of registration fees collected for training, meetings or workshops and
the proceeds from the sale of publications as a result of the federal award during the period of
performance. Program income is treated as an additive to the federal funds received by CUAHSI.
During a drawdown, program income reduces the amount that is requested to cover reimbursable
costs through the Flexible Billing module. This allows program income to be applied to the
award before a reimbursement is requested from NSF adding the value of program income
received to the awarded amount. Program income reporting is due forty five (45) days after the
end of the federal fiscal year. NSF requires that all cumulative program income is reported for all
open grants and agreements in the current year. CUAHSI program income totaled $31,525 for
the year ended December 31, 2021. CUAHSI failed to submit the required Program Income Reporting Worksheet by the required deadline of forty five (45) days after the end of the federal fiscal year (November 15, 2021) to ensure with the program income policies in accordance with the UG for the year ended December 31, 2021.
Cause & Context
Lack of resources and detailed attention to the risks, along with circumvention of controls has
resulted in weak internal controls, and conflicting or incomplete policies and procedures.
Effect
Non-compliance can lead to penalties, fines, or even termination of the contract. It may also
damage CUAHSI’s reputation and future eligibility for federal funding and jeopardize
CUAHSI’s ability to secure future grants or contracts from other funding agencies. Granting
organizations typically prioritize funding recipients with a track record of compliance and
accountability.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-009.
Recommendation
The auditor recommends that CUAHSI develops and implements controls over policies
consistent with 2 CFR 200.307.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation and U.S. Department of Agriculture
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure, Integrative Activities & Forestry Research
AL No.: 47.050, 47.070, 47.079, 47.080, 47.083 & 10.652
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022), OIA-1937099 (09/01/2020
– 08/31/2021) & 19-DG11330140-083 (09/26/2019 – 09/30/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-002 ACCURACY AND COMPLETENESS OF SCHEDULE OF EXPENDITURES OF
FEDERAL AWARDS (“SEFA”)
Material Weakness
Criteria
CUAHSI is required to prepare a SEFA in accordance with the prescribed guidelines of the
Uniform Guidance (“UG”). In addition, 2 CFR Section 200.512(a) of the Uniform Guidance
requires the reporting package and Data Collection Form (“DCF”) to be submitted to the Federal
Audit Clearinghouse the earlier of 30 calendar days after the reports are received from the
auditor or nine months after CUAHSI’s year end.
Condition
CUAHSI provided two different versions of the SEFA to the auditor during the audit process.
Additionally, due to the delay in financial close of CUAHSI’s books and records, a federal single
audit for the year ended December 31, 2021 was not performed in a timely manner and the DCF
was not submitted by its due date of September 30, 2022. The inaccurate reporting of grants and
related activity in the SEFA can lead to improper identification of major programs causing
inadequate testing by the auditor as required by UG. As a result of the audit procedures
performed and proposed adjustments to CUAHSI’s preliminary SEFA by the audit, management
was able to make the required changes.
Cause & Context
Due personnel and staffing issues, CUAHSI was not able to complete the financial close process
in a timely manner which led to the changes in qualified expenditures and delay in the financial
statement and the federal single audit being completed.
Effect
Failure to comply with federal regulations and reporting requirements exposes CUAHSI to
potential legal and regulatory consequences, including the risk of future funding loss and
financial penalties.
Questioned Costs
None
Prior Year Audit Finding
Yes - previously reported as MW2020-002.
Recommendation
To address the identified deficiencies and improve controls over the preparation of the SEFA, the
auditor recommends the development and documentation of procedures for tracking federal
awards and related disbursements to subrecipients.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation and U.S. Department of Agriculture
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure, Integrative Activities & Forestry Research
AL No.: 47.050, 47.070, 47.079, 47.080, 47.083 & 10.652
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022), OIA-1937099 (09/01/2020
– 08/31/2021) & 19-DG11330140-083 (09/26/2019 – 09/30/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-004 REPORTING - DCF
Material Weakness
Criteria
2 CFR Section 200.512(a) requires the reporting package and DCF to be submitted to the Federal
Audit Clearinghouse the earlier of thirty calendar days after the reports are received from the
auditor or nine months after the end of the audit period.
Condition
Due to the delay in financial close of CUAHSI’s books and records, a federal single audit for
fiscal year 2021 was not performed in a timely manner and the DCF was not submitted by its due
date of September 30, 2022. The UG requires the reporting package and DCF to be submitted to
the Federal Audit Clearinghouse the earlier of 30 calendar days after the reports are received
from the auditor (April 2, 2025) or nine months after CUAHSI’s year end (September 30, 2022).
Cause & Context
CUAHSI did not have effective controls in place to allow for a timely year-end closing. This
caused significant auditor delays which resulted in CUAHSI’s inability to meet the filing
requirements under the UG.
Effect
CUAHSI is not in compliance with 2 CFR Part 200, Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-004.
Recommendation
Management should implement policies to ensure timely financial reporting and ensure the
timely completion of an audit.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-005 SUBRECIPIENT MONITORING
Material Weakness
Criteria
The regulations are documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and
.501(h); (Requirements for Pass-Through Entities). The criteria for monitoring subrecipients of
federal awards should be following federal regulations, the terms of the federal contract, and any
additional requirements specified by the auditee's policies and procedures. Specifically, the
monitoring criteria should include, but not be limited to, the following:
• Subrecipient Risk Assessment
• Financial Monitoring
• Compliance Monitoring
• Reporting and Documentation
Condition
The auditee failed to comply with federal regulations requiring the monitoring of subrecipients
for federal awards on a timely basis. Recipients of federal awards are responsible for monitoring
the activities of subrecipients to ensure that they comply with applicable laws, regulations, and
the terms and conditions of the federal award. CUAHSI did not complete the monitoring of its
2021 subrecipients until 2024. During the year ended December 31, 2021, CUAHSI had
$128,472 in amounts paid to subrecipients. Based on our testing of amounts paid to
subrecipients, no amounts were identified as unallowable.
Cause & Context
CUAHSI had a policy and procedure manual in place which outlined the steps for monitoring.
There was no audit evidence of CUAHSI following the policy and monitoring that the
subrecipient was using the funding as prescribed during the year ended December 31, 2021.
Effect
CUAHSI’s lack of monitoring creates a significant risk of the possible misuse or improper use of
funds.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-005.
Recommendation
The auditor recommends that management review the requirements documented in 31 USC
7502(f)(2), 2 CFR sections 200.330, .331, and .501(h);(Requirements for Pass-Through Entities)
and develops and implements procedures to adhere to such requirements.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
Material Weakness
MW2021-006 CASH MANAGEMENT
Criteria
2 CFR Part 200 states that entities expending federal grants must establish and maintain effective
internal control over the federal award that provides reasonable assurance that the non-federal
entity is managing the federal award in compliance with federal statues, regulations, and the
terms and conditions of the Federal award. To comply with 2 CFR Part 200, CUAHSI was
required to submit monthly invoices for the funds received under the federal contract. These
invoices will serve as a record of the services or goods provided during the specified period and
will facilitate accurate tracking and reporting of the funds. In addition to the invoice, any
supporting documentation, such as timesheets, should be maintained with the invoices. The cash
management process should also be adjusted for the receipt of program income.
These documents validate the services provided and ensure transparency and auditability of the
invoiced amount. These amounts should be able to be traced to the general ledger in conjunction
with the time in which they are billed.
Condition
The cash management process requires that cash draws be reviewed and approved to ensure the
propriety of draw reimbursement requests. Management was unable to provide the auditor
evidence documenting approval of the drawdowns for the year ended December 31, 2021.
Cause & Context
CUAHSI had no fiscal management team during the year ended December 31, 2021 to ensure
compliance with proper policies and procedures. The books and records for the year ended
December 31, 2021 were recreated by the current management team during 2024 to 2025.
Effect
Grant awards and reimbursements may not be recorded correctly and there is a higher risk of
error or misappropriation of assets.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-006.
Recommendation
The auditor recommends CUAHSI develop and implement controls to ensure an adequate review
process is in place for review of reimbursement requests submitted to granting agencies to ensure
consistent reporting.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-007 PROCUREMENT, SUSPENSION AND DEBARMENT
Material Weakness
Criteria
The requirements for this compliance requirement are contained in 2 CFR sections 200.317-
200.326; 48 CFR parts 03, 15, 44, and the clauses at 48 CRF sections 52.244-2, 52.244-5,
52.203-13, 52.203-16 and 52.215-12; agency FAR supplements; 2 CFR part 180; OMB M-18-
18; and the terms and conditions of the federal award. There is a requirement to verify that
contractors in covered transactions or any of its vendors are not federally debarred, suspended, or
excluded.
A covered transaction is a nonprocurement or procurement transaction in excess of $25,000 that
is subject to the prohibitions noted in 2 CFR part 180. The covered transaction may be at the
primary tier, between a federal agency and a person or a lower tier between a participant in a
covered transaction and another person.
Condition
During the completion of the audit, the auditor noted that CUAHSI failed to maintain and
provide the proper records and support to document their review of vendor files for covered
transactions. Such failure led to non-compliance with the procurement, suspension and
debarment policies in accordance with the UG for the year ended December 31, 2021. CUAHSI
did not complete the verification of its 2021 vendors until 2024. Based on our testing, no
contractors in covered transactions were deemed to be federally debarred, suspended or
excluded. Material Weakness
Cause & Context
CUAHSI has a policy in place to meet the procurement requirements but there was no evidence
of compliance with that policy.
Effect
As a result of noncompliance, there could be possible repayment of funds, loss of reputation and
possible suspension or debarment.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-007.
Recommendation
It is recommended that CUAHSI strive to prioritize compliance. CUAHSI should ensure that, to
the extent practicable, the use of a competitive procurement process in compliance with 2 CFR
section 200/317.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-008 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF
EXPENDITURES
Material Weakness
Criteria
CFR § 200.305 Cash management: This section of the CFR outlines the requirements for the
management of cash drawdowns and disbursements of federal funds. Federal funds should be
disbursed in a timely manner for allowable costs that have been incurred. Cash advances must
meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National
Science Foundation.
Condition
CUAHSI did not meet the conditions specified in Chapter VIII.C.3 of the grant agreement with
the National Science Foundation which details the requirements for advance fundings. During
2021, CUAHSI had advance drawdowns totaling $1,172,645 from the NSF. Of this amount,
CUAHSI incurred $1,049,681 in eligible expenses for the year ended December 31, 2021. This
resulted in $122,964 in excess federal advances as of year-end. The draw downs in excess of
revenue recognized during the year ended December 31, 2021 are reported as part of deferred
revenue in the accompanying Statement of Financial Position.
Cause & Context
CUAHSI initiated advance drawdowns without following the guidelines set forth by Chapter
VIII.C.3 of the grant agreement.
Effect
Drawing down funds in advance of incurring eligible expenses could lead to non-compliance
with federal regulations, such as those outlined in 2 CFR § 200.305. This may result in the need
to repay the funds, potential financial penalties, or disqualification from future federal funding.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-008.
Recommendation
The auditor recommends that CUAHSI develops and implements controls over policies
consistent with 2 CFR 200.35.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-009 PROGRAM INCOME
Material Weakness
Criteria
Pursuant to 2 CFR 200 for award objectives and the regulations at 2 CFR 200.307, program
income is defined as “Gross income earned by the recipient that is directly generated by a
supported activity or earned as a result of the federal award during the period of performance” by
2 CFR Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements
for Federal Awards. Program income reporting is due forty five (45) days after the end of the
federal fiscal year. NSF requires that all cumulative program income is reported for all open
grants and agreements in the current year.
Condition
Program income consists of registration fees collected for training, meetings or workshops and
the proceeds from the sale of publications as a result of the federal award during the period of
performance. Program income is treated as an additive to the federal funds received by CUAHSI.
During a drawdown, program income reduces the amount that is requested to cover reimbursable
costs through the Flexible Billing module. This allows program income to be applied to the
award before a reimbursement is requested from NSF adding the value of program income
received to the awarded amount. Program income reporting is due forty five (45) days after the
end of the federal fiscal year. NSF requires that all cumulative program income is reported for all
open grants and agreements in the current year. CUAHSI program income totaled $31,525 for
the year ended December 31, 2021. CUAHSI failed to submit the required Program Income Reporting Worksheet by the required deadline of forty five (45) days after the end of the federal fiscal year (November 15, 2021) to ensure with the program income policies in accordance with the UG for the year ended December 31, 2021.
Cause & Context
Lack of resources and detailed attention to the risks, along with circumvention of controls has
resulted in weak internal controls, and conflicting or incomplete policies and procedures.
Effect
Non-compliance can lead to penalties, fines, or even termination of the contract. It may also
damage CUAHSI’s reputation and future eligibility for federal funding and jeopardize
CUAHSI’s ability to secure future grants or contracts from other funding agencies. Granting
organizations typically prioritize funding recipients with a track record of compliance and
accountability.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-009.
Recommendation
The auditor recommends that CUAHSI develops and implements controls over policies
consistent with 2 CFR 200.307.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation and U.S. Department of Agriculture
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure, Integrative Activities & Forestry Research
AL No.: 47.050, 47.070, 47.079, 47.080, 47.083 & 10.652
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022), OIA-1937099 (09/01/2020
– 08/31/2021) & 19-DG11330140-083 (09/26/2019 – 09/30/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-002 ACCURACY AND COMPLETENESS OF SCHEDULE OF EXPENDITURES OF
FEDERAL AWARDS (“SEFA”)
Material Weakness
Criteria
CUAHSI is required to prepare a SEFA in accordance with the prescribed guidelines of the
Uniform Guidance (“UG”). In addition, 2 CFR Section 200.512(a) of the Uniform Guidance
requires the reporting package and Data Collection Form (“DCF”) to be submitted to the Federal
Audit Clearinghouse the earlier of 30 calendar days after the reports are received from the
auditor or nine months after CUAHSI’s year end.
Condition
CUAHSI provided two different versions of the SEFA to the auditor during the audit process.
Additionally, due to the delay in financial close of CUAHSI’s books and records, a federal single
audit for the year ended December 31, 2021 was not performed in a timely manner and the DCF
was not submitted by its due date of September 30, 2022. The inaccurate reporting of grants and
related activity in the SEFA can lead to improper identification of major programs causing
inadequate testing by the auditor as required by UG. As a result of the audit procedures
performed and proposed adjustments to CUAHSI’s preliminary SEFA by the audit, management
was able to make the required changes.
Cause & Context
Due personnel and staffing issues, CUAHSI was not able to complete the financial close process
in a timely manner which led to the changes in qualified expenditures and delay in the financial
statement and the federal single audit being completed.
Effect
Failure to comply with federal regulations and reporting requirements exposes CUAHSI to
potential legal and regulatory consequences, including the risk of future funding loss and
financial penalties.
Questioned Costs
None
Prior Year Audit Finding
Yes - previously reported as MW2020-002.
Recommendation
To address the identified deficiencies and improve controls over the preparation of the SEFA, the
auditor recommends the development and documentation of procedures for tracking federal
awards and related disbursements to subrecipients.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation and U.S. Department of Agriculture
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure, Integrative Activities & Forestry Research
AL No.: 47.050, 47.070, 47.079, 47.080, 47.083 & 10.652
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022), OIA-1937099 (09/01/2020
– 08/31/2021) & 19-DG11330140-083 (09/26/2019 – 09/30/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-004 REPORTING - DCF
Material Weakness
Criteria
2 CFR Section 200.512(a) requires the reporting package and DCF to be submitted to the Federal
Audit Clearinghouse the earlier of thirty calendar days after the reports are received from the
auditor or nine months after the end of the audit period.
Condition
Due to the delay in financial close of CUAHSI’s books and records, a federal single audit for
fiscal year 2021 was not performed in a timely manner and the DCF was not submitted by its due
date of September 30, 2022. The UG requires the reporting package and DCF to be submitted to
the Federal Audit Clearinghouse the earlier of 30 calendar days after the reports are received
from the auditor (April 2, 2025) or nine months after CUAHSI’s year end (September 30, 2022).
Cause & Context
CUAHSI did not have effective controls in place to allow for a timely year-end closing. This
caused significant auditor delays which resulted in CUAHSI’s inability to meet the filing
requirements under the UG.
Effect
CUAHSI is not in compliance with 2 CFR Part 200, Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-004.
Recommendation
Management should implement policies to ensure timely financial reporting and ensure the
timely completion of an audit.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-005 SUBRECIPIENT MONITORING
Material Weakness
Criteria
The regulations are documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and
.501(h); (Requirements for Pass-Through Entities). The criteria for monitoring subrecipients of
federal awards should be following federal regulations, the terms of the federal contract, and any
additional requirements specified by the auditee's policies and procedures. Specifically, the
monitoring criteria should include, but not be limited to, the following:
• Subrecipient Risk Assessment
• Financial Monitoring
• Compliance Monitoring
• Reporting and Documentation
Condition
The auditee failed to comply with federal regulations requiring the monitoring of subrecipients
for federal awards on a timely basis. Recipients of federal awards are responsible for monitoring
the activities of subrecipients to ensure that they comply with applicable laws, regulations, and
the terms and conditions of the federal award. CUAHSI did not complete the monitoring of its
2021 subrecipients until 2024. During the year ended December 31, 2021, CUAHSI had
$128,472 in amounts paid to subrecipients. Based on our testing of amounts paid to
subrecipients, no amounts were identified as unallowable.
Cause & Context
CUAHSI had a policy and procedure manual in place which outlined the steps for monitoring.
There was no audit evidence of CUAHSI following the policy and monitoring that the
subrecipient was using the funding as prescribed during the year ended December 31, 2021.
Effect
CUAHSI’s lack of monitoring creates a significant risk of the possible misuse or improper use of
funds.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-005.
Recommendation
The auditor recommends that management review the requirements documented in 31 USC
7502(f)(2), 2 CFR sections 200.330, .331, and .501(h);(Requirements for Pass-Through Entities)
and develops and implements procedures to adhere to such requirements.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
Material Weakness
MW2021-006 CASH MANAGEMENT
Criteria
2 CFR Part 200 states that entities expending federal grants must establish and maintain effective
internal control over the federal award that provides reasonable assurance that the non-federal
entity is managing the federal award in compliance with federal statues, regulations, and the
terms and conditions of the Federal award. To comply with 2 CFR Part 200, CUAHSI was
required to submit monthly invoices for the funds received under the federal contract. These
invoices will serve as a record of the services or goods provided during the specified period and
will facilitate accurate tracking and reporting of the funds. In addition to the invoice, any
supporting documentation, such as timesheets, should be maintained with the invoices. The cash
management process should also be adjusted for the receipt of program income.
These documents validate the services provided and ensure transparency and auditability of the
invoiced amount. These amounts should be able to be traced to the general ledger in conjunction
with the time in which they are billed.
Condition
The cash management process requires that cash draws be reviewed and approved to ensure the
propriety of draw reimbursement requests. Management was unable to provide the auditor
evidence documenting approval of the drawdowns for the year ended December 31, 2021.
Cause & Context
CUAHSI had no fiscal management team during the year ended December 31, 2021 to ensure
compliance with proper policies and procedures. The books and records for the year ended
December 31, 2021 were recreated by the current management team during 2024 to 2025.
Effect
Grant awards and reimbursements may not be recorded correctly and there is a higher risk of
error or misappropriation of assets.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-006.
Recommendation
The auditor recommends CUAHSI develop and implement controls to ensure an adequate review
process is in place for review of reimbursement requests submitted to granting agencies to ensure
consistent reporting.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-007 PROCUREMENT, SUSPENSION AND DEBARMENT
Material Weakness
Criteria
The requirements for this compliance requirement are contained in 2 CFR sections 200.317-
200.326; 48 CFR parts 03, 15, 44, and the clauses at 48 CRF sections 52.244-2, 52.244-5,
52.203-13, 52.203-16 and 52.215-12; agency FAR supplements; 2 CFR part 180; OMB M-18-
18; and the terms and conditions of the federal award. There is a requirement to verify that
contractors in covered transactions or any of its vendors are not federally debarred, suspended, or
excluded.
A covered transaction is a nonprocurement or procurement transaction in excess of $25,000 that
is subject to the prohibitions noted in 2 CFR part 180. The covered transaction may be at the
primary tier, between a federal agency and a person or a lower tier between a participant in a
covered transaction and another person.
Condition
During the completion of the audit, the auditor noted that CUAHSI failed to maintain and
provide the proper records and support to document their review of vendor files for covered
transactions. Such failure led to non-compliance with the procurement, suspension and
debarment policies in accordance with the UG for the year ended December 31, 2021. CUAHSI
did not complete the verification of its 2021 vendors until 2024. Based on our testing, no
contractors in covered transactions were deemed to be federally debarred, suspended or
excluded. Material Weakness
Cause & Context
CUAHSI has a policy in place to meet the procurement requirements but there was no evidence
of compliance with that policy.
Effect
As a result of noncompliance, there could be possible repayment of funds, loss of reputation and
possible suspension or debarment.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-007.
Recommendation
It is recommended that CUAHSI strive to prioritize compliance. CUAHSI should ensure that, to
the extent practicable, the use of a competitive procurement process in compliance with 2 CFR
section 200/317.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-008 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF
EXPENDITURES
Material Weakness
Criteria
CFR § 200.305 Cash management: This section of the CFR outlines the requirements for the
management of cash drawdowns and disbursements of federal funds. Federal funds should be
disbursed in a timely manner for allowable costs that have been incurred. Cash advances must
meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National
Science Foundation.
Condition
CUAHSI did not meet the conditions specified in Chapter VIII.C.3 of the grant agreement with
the National Science Foundation which details the requirements for advance fundings. During
2021, CUAHSI had advance drawdowns totaling $1,172,645 from the NSF. Of this amount,
CUAHSI incurred $1,049,681 in eligible expenses for the year ended December 31, 2021. This
resulted in $122,964 in excess federal advances as of year-end. The draw downs in excess of
revenue recognized during the year ended December 31, 2021 are reported as part of deferred
revenue in the accompanying Statement of Financial Position.
Cause & Context
CUAHSI initiated advance drawdowns without following the guidelines set forth by Chapter
VIII.C.3 of the grant agreement.
Effect
Drawing down funds in advance of incurring eligible expenses could lead to non-compliance
with federal regulations, such as those outlined in 2 CFR § 200.305. This may result in the need
to repay the funds, potential financial penalties, or disqualification from future federal funding.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-008.
Recommendation
The auditor recommends that CUAHSI develops and implements controls over policies
consistent with 2 CFR 200.35.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-009 PROGRAM INCOME
Material Weakness
Criteria
Pursuant to 2 CFR 200 for award objectives and the regulations at 2 CFR 200.307, program
income is defined as “Gross income earned by the recipient that is directly generated by a
supported activity or earned as a result of the federal award during the period of performance” by
2 CFR Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements
for Federal Awards. Program income reporting is due forty five (45) days after the end of the
federal fiscal year. NSF requires that all cumulative program income is reported for all open
grants and agreements in the current year.
Condition
Program income consists of registration fees collected for training, meetings or workshops and
the proceeds from the sale of publications as a result of the federal award during the period of
performance. Program income is treated as an additive to the federal funds received by CUAHSI.
During a drawdown, program income reduces the amount that is requested to cover reimbursable
costs through the Flexible Billing module. This allows program income to be applied to the
award before a reimbursement is requested from NSF adding the value of program income
received to the awarded amount. Program income reporting is due forty five (45) days after the
end of the federal fiscal year. NSF requires that all cumulative program income is reported for all
open grants and agreements in the current year. CUAHSI program income totaled $31,525 for
the year ended December 31, 2021. CUAHSI failed to submit the required Program Income Reporting Worksheet by the required deadline of forty five (45) days after the end of the federal fiscal year (November 15, 2021) to ensure with the program income policies in accordance with the UG for the year ended December 31, 2021.
Cause & Context
Lack of resources and detailed attention to the risks, along with circumvention of controls has
resulted in weak internal controls, and conflicting or incomplete policies and procedures.
Effect
Non-compliance can lead to penalties, fines, or even termination of the contract. It may also
damage CUAHSI’s reputation and future eligibility for federal funding and jeopardize
CUAHSI’s ability to secure future grants or contracts from other funding agencies. Granting
organizations typically prioritize funding recipients with a track record of compliance and
accountability.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-009.
Recommendation
The auditor recommends that CUAHSI develops and implements controls over policies
consistent with 2 CFR 200.307.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation and U.S. Department of Agriculture
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure, Integrative Activities & Forestry Research
AL No.: 47.050, 47.070, 47.079, 47.080, 47.083 & 10.652
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022), OIA-1937099 (09/01/2020
– 08/31/2021) & 19-DG11330140-083 (09/26/2019 – 09/30/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-002 ACCURACY AND COMPLETENESS OF SCHEDULE OF EXPENDITURES OF
FEDERAL AWARDS (“SEFA”)
Material Weakness
Criteria
CUAHSI is required to prepare a SEFA in accordance with the prescribed guidelines of the
Uniform Guidance (“UG”). In addition, 2 CFR Section 200.512(a) of the Uniform Guidance
requires the reporting package and Data Collection Form (“DCF”) to be submitted to the Federal
Audit Clearinghouse the earlier of 30 calendar days after the reports are received from the
auditor or nine months after CUAHSI’s year end.
Condition
CUAHSI provided two different versions of the SEFA to the auditor during the audit process.
Additionally, due to the delay in financial close of CUAHSI’s books and records, a federal single
audit for the year ended December 31, 2021 was not performed in a timely manner and the DCF
was not submitted by its due date of September 30, 2022. The inaccurate reporting of grants and
related activity in the SEFA can lead to improper identification of major programs causing
inadequate testing by the auditor as required by UG. As a result of the audit procedures
performed and proposed adjustments to CUAHSI’s preliminary SEFA by the audit, management
was able to make the required changes.
Cause & Context
Due personnel and staffing issues, CUAHSI was not able to complete the financial close process
in a timely manner which led to the changes in qualified expenditures and delay in the financial
statement and the federal single audit being completed.
Effect
Failure to comply with federal regulations and reporting requirements exposes CUAHSI to
potential legal and regulatory consequences, including the risk of future funding loss and
financial penalties.
Questioned Costs
None
Prior Year Audit Finding
Yes - previously reported as MW2020-002.
Recommendation
To address the identified deficiencies and improve controls over the preparation of the SEFA, the
auditor recommends the development and documentation of procedures for tracking federal
awards and related disbursements to subrecipients.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation and U.S. Department of Agriculture
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure, Integrative Activities & Forestry Research
AL No.: 47.050, 47.070, 47.079, 47.080, 47.083 & 10.652
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022), OIA-1937099 (09/01/2020
– 08/31/2021) & 19-DG11330140-083 (09/26/2019 – 09/30/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-004 REPORTING - DCF
Material Weakness
Criteria
2 CFR Section 200.512(a) requires the reporting package and DCF to be submitted to the Federal
Audit Clearinghouse the earlier of thirty calendar days after the reports are received from the
auditor or nine months after the end of the audit period.
Condition
Due to the delay in financial close of CUAHSI’s books and records, a federal single audit for
fiscal year 2021 was not performed in a timely manner and the DCF was not submitted by its due
date of September 30, 2022. The UG requires the reporting package and DCF to be submitted to
the Federal Audit Clearinghouse the earlier of 30 calendar days after the reports are received
from the auditor (April 2, 2025) or nine months after CUAHSI’s year end (September 30, 2022).
Cause & Context
CUAHSI did not have effective controls in place to allow for a timely year-end closing. This
caused significant auditor delays which resulted in CUAHSI’s inability to meet the filing
requirements under the UG.
Effect
CUAHSI is not in compliance with 2 CFR Part 200, Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-004.
Recommendation
Management should implement policies to ensure timely financial reporting and ensure the
timely completion of an audit.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-005 SUBRECIPIENT MONITORING
Material Weakness
Criteria
The regulations are documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and
.501(h); (Requirements for Pass-Through Entities). The criteria for monitoring subrecipients of
federal awards should be following federal regulations, the terms of the federal contract, and any
additional requirements specified by the auditee's policies and procedures. Specifically, the
monitoring criteria should include, but not be limited to, the following:
• Subrecipient Risk Assessment
• Financial Monitoring
• Compliance Monitoring
• Reporting and Documentation
Condition
The auditee failed to comply with federal regulations requiring the monitoring of subrecipients
for federal awards on a timely basis. Recipients of federal awards are responsible for monitoring
the activities of subrecipients to ensure that they comply with applicable laws, regulations, and
the terms and conditions of the federal award. CUAHSI did not complete the monitoring of its
2021 subrecipients until 2024. During the year ended December 31, 2021, CUAHSI had
$128,472 in amounts paid to subrecipients. Based on our testing of amounts paid to
subrecipients, no amounts were identified as unallowable.
Cause & Context
CUAHSI had a policy and procedure manual in place which outlined the steps for monitoring.
There was no audit evidence of CUAHSI following the policy and monitoring that the
subrecipient was using the funding as prescribed during the year ended December 31, 2021.
Effect
CUAHSI’s lack of monitoring creates a significant risk of the possible misuse or improper use of
funds.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-005.
Recommendation
The auditor recommends that management review the requirements documented in 31 USC
7502(f)(2), 2 CFR sections 200.330, .331, and .501(h);(Requirements for Pass-Through Entities)
and develops and implements procedures to adhere to such requirements.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
Material Weakness
MW2021-006 CASH MANAGEMENT
Criteria
2 CFR Part 200 states that entities expending federal grants must establish and maintain effective
internal control over the federal award that provides reasonable assurance that the non-federal
entity is managing the federal award in compliance with federal statues, regulations, and the
terms and conditions of the Federal award. To comply with 2 CFR Part 200, CUAHSI was
required to submit monthly invoices for the funds received under the federal contract. These
invoices will serve as a record of the services or goods provided during the specified period and
will facilitate accurate tracking and reporting of the funds. In addition to the invoice, any
supporting documentation, such as timesheets, should be maintained with the invoices. The cash
management process should also be adjusted for the receipt of program income.
These documents validate the services provided and ensure transparency and auditability of the
invoiced amount. These amounts should be able to be traced to the general ledger in conjunction
with the time in which they are billed.
Condition
The cash management process requires that cash draws be reviewed and approved to ensure the
propriety of draw reimbursement requests. Management was unable to provide the auditor
evidence documenting approval of the drawdowns for the year ended December 31, 2021.
Cause & Context
CUAHSI had no fiscal management team during the year ended December 31, 2021 to ensure
compliance with proper policies and procedures. The books and records for the year ended
December 31, 2021 were recreated by the current management team during 2024 to 2025.
Effect
Grant awards and reimbursements may not be recorded correctly and there is a higher risk of
error or misappropriation of assets.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-006.
Recommendation
The auditor recommends CUAHSI develop and implement controls to ensure an adequate review
process is in place for review of reimbursement requests submitted to granting agencies to ensure
consistent reporting.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-007 PROCUREMENT, SUSPENSION AND DEBARMENT
Material Weakness
Criteria
The requirements for this compliance requirement are contained in 2 CFR sections 200.317-
200.326; 48 CFR parts 03, 15, 44, and the clauses at 48 CRF sections 52.244-2, 52.244-5,
52.203-13, 52.203-16 and 52.215-12; agency FAR supplements; 2 CFR part 180; OMB M-18-
18; and the terms and conditions of the federal award. There is a requirement to verify that
contractors in covered transactions or any of its vendors are not federally debarred, suspended, or
excluded.
A covered transaction is a nonprocurement or procurement transaction in excess of $25,000 that
is subject to the prohibitions noted in 2 CFR part 180. The covered transaction may be at the
primary tier, between a federal agency and a person or a lower tier between a participant in a
covered transaction and another person.
Condition
During the completion of the audit, the auditor noted that CUAHSI failed to maintain and
provide the proper records and support to document their review of vendor files for covered
transactions. Such failure led to non-compliance with the procurement, suspension and
debarment policies in accordance with the UG for the year ended December 31, 2021. CUAHSI
did not complete the verification of its 2021 vendors until 2024. Based on our testing, no
contractors in covered transactions were deemed to be federally debarred, suspended or
excluded. Material Weakness
Cause & Context
CUAHSI has a policy in place to meet the procurement requirements but there was no evidence
of compliance with that policy.
Effect
As a result of noncompliance, there could be possible repayment of funds, loss of reputation and
possible suspension or debarment.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-007.
Recommendation
It is recommended that CUAHSI strive to prioritize compliance. CUAHSI should ensure that, to
the extent practicable, the use of a competitive procurement process in compliance with 2 CFR
section 200/317.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-008 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF
EXPENDITURES
Material Weakness
Criteria
CFR § 200.305 Cash management: This section of the CFR outlines the requirements for the
management of cash drawdowns and disbursements of federal funds. Federal funds should be
disbursed in a timely manner for allowable costs that have been incurred. Cash advances must
meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National
Science Foundation.
Condition
CUAHSI did not meet the conditions specified in Chapter VIII.C.3 of the grant agreement with
the National Science Foundation which details the requirements for advance fundings. During
2021, CUAHSI had advance drawdowns totaling $1,172,645 from the NSF. Of this amount,
CUAHSI incurred $1,049,681 in eligible expenses for the year ended December 31, 2021. This
resulted in $122,964 in excess federal advances as of year-end. The draw downs in excess of
revenue recognized during the year ended December 31, 2021 are reported as part of deferred
revenue in the accompanying Statement of Financial Position.
Cause & Context
CUAHSI initiated advance drawdowns without following the guidelines set forth by Chapter
VIII.C.3 of the grant agreement.
Effect
Drawing down funds in advance of incurring eligible expenses could lead to non-compliance
with federal regulations, such as those outlined in 2 CFR § 200.305. This may result in the need
to repay the funds, potential financial penalties, or disqualification from future federal funding.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-008.
Recommendation
The auditor recommends that CUAHSI develops and implements controls over policies
consistent with 2 CFR 200.35.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-009 PROGRAM INCOME
Material Weakness
Criteria
Pursuant to 2 CFR 200 for award objectives and the regulations at 2 CFR 200.307, program
income is defined as “Gross income earned by the recipient that is directly generated by a
supported activity or earned as a result of the federal award during the period of performance” by
2 CFR Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements
for Federal Awards. Program income reporting is due forty five (45) days after the end of the
federal fiscal year. NSF requires that all cumulative program income is reported for all open
grants and agreements in the current year.
Condition
Program income consists of registration fees collected for training, meetings or workshops and
the proceeds from the sale of publications as a result of the federal award during the period of
performance. Program income is treated as an additive to the federal funds received by CUAHSI.
During a drawdown, program income reduces the amount that is requested to cover reimbursable
costs through the Flexible Billing module. This allows program income to be applied to the
award before a reimbursement is requested from NSF adding the value of program income
received to the awarded amount. Program income reporting is due forty five (45) days after the
end of the federal fiscal year. NSF requires that all cumulative program income is reported for all
open grants and agreements in the current year. CUAHSI program income totaled $31,525 for
the year ended December 31, 2021. CUAHSI failed to submit the required Program Income Reporting Worksheet by the required deadline of forty five (45) days after the end of the federal fiscal year (November 15, 2021) to ensure with the program income policies in accordance with the UG for the year ended December 31, 2021.
Cause & Context
Lack of resources and detailed attention to the risks, along with circumvention of controls has
resulted in weak internal controls, and conflicting or incomplete policies and procedures.
Effect
Non-compliance can lead to penalties, fines, or even termination of the contract. It may also
damage CUAHSI’s reputation and future eligibility for federal funding and jeopardize
CUAHSI’s ability to secure future grants or contracts from other funding agencies. Granting
organizations typically prioritize funding recipients with a track record of compliance and
accountability.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-009.
Recommendation
The auditor recommends that CUAHSI develops and implements controls over policies
consistent with 2 CFR 200.307.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation and U.S. Department of Agriculture
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure, Integrative Activities & Forestry Research
AL No.: 47.050, 47.070, 47.079, 47.080, 47.083 & 10.652
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022), OIA-1937099 (09/01/2020
– 08/31/2021) & 19-DG11330140-083 (09/26/2019 – 09/30/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-002 ACCURACY AND COMPLETENESS OF SCHEDULE OF EXPENDITURES OF
FEDERAL AWARDS (“SEFA”)
Material Weakness
Criteria
CUAHSI is required to prepare a SEFA in accordance with the prescribed guidelines of the
Uniform Guidance (“UG”). In addition, 2 CFR Section 200.512(a) of the Uniform Guidance
requires the reporting package and Data Collection Form (“DCF”) to be submitted to the Federal
Audit Clearinghouse the earlier of 30 calendar days after the reports are received from the
auditor or nine months after CUAHSI’s year end.
Condition
CUAHSI provided two different versions of the SEFA to the auditor during the audit process.
Additionally, due to the delay in financial close of CUAHSI’s books and records, a federal single
audit for the year ended December 31, 2021 was not performed in a timely manner and the DCF
was not submitted by its due date of September 30, 2022. The inaccurate reporting of grants and
related activity in the SEFA can lead to improper identification of major programs causing
inadequate testing by the auditor as required by UG. As a result of the audit procedures
performed and proposed adjustments to CUAHSI’s preliminary SEFA by the audit, management
was able to make the required changes.
Cause & Context
Due personnel and staffing issues, CUAHSI was not able to complete the financial close process
in a timely manner which led to the changes in qualified expenditures and delay in the financial
statement and the federal single audit being completed.
Effect
Failure to comply with federal regulations and reporting requirements exposes CUAHSI to
potential legal and regulatory consequences, including the risk of future funding loss and
financial penalties.
Questioned Costs
None
Prior Year Audit Finding
Yes - previously reported as MW2020-002.
Recommendation
To address the identified deficiencies and improve controls over the preparation of the SEFA, the
auditor recommends the development and documentation of procedures for tracking federal
awards and related disbursements to subrecipients.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation and U.S. Department of Agriculture
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure, Integrative Activities & Forestry Research
AL No.: 47.050, 47.070, 47.079, 47.080, 47.083 & 10.652
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022), OIA-1937099 (09/01/2020
– 08/31/2021) & 19-DG11330140-083 (09/26/2019 – 09/30/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-004 REPORTING - DCF
Material Weakness
Criteria
2 CFR Section 200.512(a) requires the reporting package and DCF to be submitted to the Federal
Audit Clearinghouse the earlier of thirty calendar days after the reports are received from the
auditor or nine months after the end of the audit period.
Condition
Due to the delay in financial close of CUAHSI’s books and records, a federal single audit for
fiscal year 2021 was not performed in a timely manner and the DCF was not submitted by its due
date of September 30, 2022. The UG requires the reporting package and DCF to be submitted to
the Federal Audit Clearinghouse the earlier of 30 calendar days after the reports are received
from the auditor (April 2, 2025) or nine months after CUAHSI’s year end (September 30, 2022).
Cause & Context
CUAHSI did not have effective controls in place to allow for a timely year-end closing. This
caused significant auditor delays which resulted in CUAHSI’s inability to meet the filing
requirements under the UG.
Effect
CUAHSI is not in compliance with 2 CFR Part 200, Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-004.
Recommendation
Management should implement policies to ensure timely financial reporting and ensure the
timely completion of an audit.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-005 SUBRECIPIENT MONITORING
Material Weakness
Criteria
The regulations are documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and
.501(h); (Requirements for Pass-Through Entities). The criteria for monitoring subrecipients of
federal awards should be following federal regulations, the terms of the federal contract, and any
additional requirements specified by the auditee's policies and procedures. Specifically, the
monitoring criteria should include, but not be limited to, the following:
• Subrecipient Risk Assessment
• Financial Monitoring
• Compliance Monitoring
• Reporting and Documentation
Condition
The auditee failed to comply with federal regulations requiring the monitoring of subrecipients
for federal awards on a timely basis. Recipients of federal awards are responsible for monitoring
the activities of subrecipients to ensure that they comply with applicable laws, regulations, and
the terms and conditions of the federal award. CUAHSI did not complete the monitoring of its
2021 subrecipients until 2024. During the year ended December 31, 2021, CUAHSI had
$128,472 in amounts paid to subrecipients. Based on our testing of amounts paid to
subrecipients, no amounts were identified as unallowable.
Cause & Context
CUAHSI had a policy and procedure manual in place which outlined the steps for monitoring.
There was no audit evidence of CUAHSI following the policy and monitoring that the
subrecipient was using the funding as prescribed during the year ended December 31, 2021.
Effect
CUAHSI’s lack of monitoring creates a significant risk of the possible misuse or improper use of
funds.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-005.
Recommendation
The auditor recommends that management review the requirements documented in 31 USC
7502(f)(2), 2 CFR sections 200.330, .331, and .501(h);(Requirements for Pass-Through Entities)
and develops and implements procedures to adhere to such requirements.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
Material Weakness
MW2021-006 CASH MANAGEMENT
Criteria
2 CFR Part 200 states that entities expending federal grants must establish and maintain effective
internal control over the federal award that provides reasonable assurance that the non-federal
entity is managing the federal award in compliance with federal statues, regulations, and the
terms and conditions of the Federal award. To comply with 2 CFR Part 200, CUAHSI was
required to submit monthly invoices for the funds received under the federal contract. These
invoices will serve as a record of the services or goods provided during the specified period and
will facilitate accurate tracking and reporting of the funds. In addition to the invoice, any
supporting documentation, such as timesheets, should be maintained with the invoices. The cash
management process should also be adjusted for the receipt of program income.
These documents validate the services provided and ensure transparency and auditability of the
invoiced amount. These amounts should be able to be traced to the general ledger in conjunction
with the time in which they are billed.
Condition
The cash management process requires that cash draws be reviewed and approved to ensure the
propriety of draw reimbursement requests. Management was unable to provide the auditor
evidence documenting approval of the drawdowns for the year ended December 31, 2021.
Cause & Context
CUAHSI had no fiscal management team during the year ended December 31, 2021 to ensure
compliance with proper policies and procedures. The books and records for the year ended
December 31, 2021 were recreated by the current management team during 2024 to 2025.
Effect
Grant awards and reimbursements may not be recorded correctly and there is a higher risk of
error or misappropriation of assets.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-006.
Recommendation
The auditor recommends CUAHSI develop and implement controls to ensure an adequate review
process is in place for review of reimbursement requests submitted to granting agencies to ensure
consistent reporting.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-007 PROCUREMENT, SUSPENSION AND DEBARMENT
Material Weakness
Criteria
The requirements for this compliance requirement are contained in 2 CFR sections 200.317-
200.326; 48 CFR parts 03, 15, 44, and the clauses at 48 CRF sections 52.244-2, 52.244-5,
52.203-13, 52.203-16 and 52.215-12; agency FAR supplements; 2 CFR part 180; OMB M-18-
18; and the terms and conditions of the federal award. There is a requirement to verify that
contractors in covered transactions or any of its vendors are not federally debarred, suspended, or
excluded.
A covered transaction is a nonprocurement or procurement transaction in excess of $25,000 that
is subject to the prohibitions noted in 2 CFR part 180. The covered transaction may be at the
primary tier, between a federal agency and a person or a lower tier between a participant in a
covered transaction and another person.
Condition
During the completion of the audit, the auditor noted that CUAHSI failed to maintain and
provide the proper records and support to document their review of vendor files for covered
transactions. Such failure led to non-compliance with the procurement, suspension and
debarment policies in accordance with the UG for the year ended December 31, 2021. CUAHSI
did not complete the verification of its 2021 vendors until 2024. Based on our testing, no
contractors in covered transactions were deemed to be federally debarred, suspended or
excluded. Material Weakness
Cause & Context
CUAHSI has a policy in place to meet the procurement requirements but there was no evidence
of compliance with that policy.
Effect
As a result of noncompliance, there could be possible repayment of funds, loss of reputation and
possible suspension or debarment.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-007.
Recommendation
It is recommended that CUAHSI strive to prioritize compliance. CUAHSI should ensure that, to
the extent practicable, the use of a competitive procurement process in compliance with 2 CFR
section 200/317.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-008 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF
EXPENDITURES
Material Weakness
Criteria
CFR § 200.305 Cash management: This section of the CFR outlines the requirements for the
management of cash drawdowns and disbursements of federal funds. Federal funds should be
disbursed in a timely manner for allowable costs that have been incurred. Cash advances must
meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National
Science Foundation.
Condition
CUAHSI did not meet the conditions specified in Chapter VIII.C.3 of the grant agreement with
the National Science Foundation which details the requirements for advance fundings. During
2021, CUAHSI had advance drawdowns totaling $1,172,645 from the NSF. Of this amount,
CUAHSI incurred $1,049,681 in eligible expenses for the year ended December 31, 2021. This
resulted in $122,964 in excess federal advances as of year-end. The draw downs in excess of
revenue recognized during the year ended December 31, 2021 are reported as part of deferred
revenue in the accompanying Statement of Financial Position.
Cause & Context
CUAHSI initiated advance drawdowns without following the guidelines set forth by Chapter
VIII.C.3 of the grant agreement.
Effect
Drawing down funds in advance of incurring eligible expenses could lead to non-compliance
with federal regulations, such as those outlined in 2 CFR § 200.305. This may result in the need
to repay the funds, potential financial penalties, or disqualification from future federal funding.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-008.
Recommendation
The auditor recommends that CUAHSI develops and implements controls over policies
consistent with 2 CFR 200.35.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-009 PROGRAM INCOME
Material Weakness
Criteria
Pursuant to 2 CFR 200 for award objectives and the regulations at 2 CFR 200.307, program
income is defined as “Gross income earned by the recipient that is directly generated by a
supported activity or earned as a result of the federal award during the period of performance” by
2 CFR Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements
for Federal Awards. Program income reporting is due forty five (45) days after the end of the
federal fiscal year. NSF requires that all cumulative program income is reported for all open
grants and agreements in the current year.
Condition
Program income consists of registration fees collected for training, meetings or workshops and
the proceeds from the sale of publications as a result of the federal award during the period of
performance. Program income is treated as an additive to the federal funds received by CUAHSI.
During a drawdown, program income reduces the amount that is requested to cover reimbursable
costs through the Flexible Billing module. This allows program income to be applied to the
award before a reimbursement is requested from NSF adding the value of program income
received to the awarded amount. Program income reporting is due forty five (45) days after the
end of the federal fiscal year. NSF requires that all cumulative program income is reported for all
open grants and agreements in the current year. CUAHSI program income totaled $31,525 for
the year ended December 31, 2021. CUAHSI failed to submit the required Program Income Reporting Worksheet by the required deadline of forty five (45) days after the end of the federal fiscal year (November 15, 2021) to ensure with the program income policies in accordance with the UG for the year ended December 31, 2021.
Cause & Context
Lack of resources and detailed attention to the risks, along with circumvention of controls has
resulted in weak internal controls, and conflicting or incomplete policies and procedures.
Effect
Non-compliance can lead to penalties, fines, or even termination of the contract. It may also
damage CUAHSI’s reputation and future eligibility for federal funding and jeopardize
CUAHSI’s ability to secure future grants or contracts from other funding agencies. Granting
organizations typically prioritize funding recipients with a track record of compliance and
accountability.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-009.
Recommendation
The auditor recommends that CUAHSI develops and implements controls over policies
consistent with 2 CFR 200.307.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation and U.S. Department of Agriculture
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure, Integrative Activities & Forestry Research
AL No.: 47.050, 47.070, 47.079, 47.080, 47.083 & 10.652
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022), OIA-1937099 (09/01/2020
– 08/31/2021) & 19-DG11330140-083 (09/26/2019 – 09/30/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-002 ACCURACY AND COMPLETENESS OF SCHEDULE OF EXPENDITURES OF
FEDERAL AWARDS (“SEFA”)
Material Weakness
Criteria
CUAHSI is required to prepare a SEFA in accordance with the prescribed guidelines of the
Uniform Guidance (“UG”). In addition, 2 CFR Section 200.512(a) of the Uniform Guidance
requires the reporting package and Data Collection Form (“DCF”) to be submitted to the Federal
Audit Clearinghouse the earlier of 30 calendar days after the reports are received from the
auditor or nine months after CUAHSI’s year end.
Condition
CUAHSI provided two different versions of the SEFA to the auditor during the audit process.
Additionally, due to the delay in financial close of CUAHSI’s books and records, a federal single
audit for the year ended December 31, 2021 was not performed in a timely manner and the DCF
was not submitted by its due date of September 30, 2022. The inaccurate reporting of grants and
related activity in the SEFA can lead to improper identification of major programs causing
inadequate testing by the auditor as required by UG. As a result of the audit procedures
performed and proposed adjustments to CUAHSI’s preliminary SEFA by the audit, management
was able to make the required changes.
Cause & Context
Due personnel and staffing issues, CUAHSI was not able to complete the financial close process
in a timely manner which led to the changes in qualified expenditures and delay in the financial
statement and the federal single audit being completed.
Effect
Failure to comply with federal regulations and reporting requirements exposes CUAHSI to
potential legal and regulatory consequences, including the risk of future funding loss and
financial penalties.
Questioned Costs
None
Prior Year Audit Finding
Yes - previously reported as MW2020-002.
Recommendation
To address the identified deficiencies and improve controls over the preparation of the SEFA, the
auditor recommends the development and documentation of procedures for tracking federal
awards and related disbursements to subrecipients.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation and U.S. Department of Agriculture
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure, Integrative Activities & Forestry Research
AL No.: 47.050, 47.070, 47.079, 47.080, 47.083 & 10.652
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022), OIA-1937099 (09/01/2020
– 08/31/2021) & 19-DG11330140-083 (09/26/2019 – 09/30/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-004 REPORTING - DCF
Material Weakness
Criteria
2 CFR Section 200.512(a) requires the reporting package and DCF to be submitted to the Federal
Audit Clearinghouse the earlier of thirty calendar days after the reports are received from the
auditor or nine months after the end of the audit period.
Condition
Due to the delay in financial close of CUAHSI’s books and records, a federal single audit for
fiscal year 2021 was not performed in a timely manner and the DCF was not submitted by its due
date of September 30, 2022. The UG requires the reporting package and DCF to be submitted to
the Federal Audit Clearinghouse the earlier of 30 calendar days after the reports are received
from the auditor (April 2, 2025) or nine months after CUAHSI’s year end (September 30, 2022).
Cause & Context
CUAHSI did not have effective controls in place to allow for a timely year-end closing. This
caused significant auditor delays which resulted in CUAHSI’s inability to meet the filing
requirements under the UG.
Effect
CUAHSI is not in compliance with 2 CFR Part 200, Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-004.
Recommendation
Management should implement policies to ensure timely financial reporting and ensure the
timely completion of an audit.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-005 SUBRECIPIENT MONITORING
Material Weakness
Criteria
The regulations are documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and
.501(h); (Requirements for Pass-Through Entities). The criteria for monitoring subrecipients of
federal awards should be following federal regulations, the terms of the federal contract, and any
additional requirements specified by the auditee's policies and procedures. Specifically, the
monitoring criteria should include, but not be limited to, the following:
• Subrecipient Risk Assessment
• Financial Monitoring
• Compliance Monitoring
• Reporting and Documentation
Condition
The auditee failed to comply with federal regulations requiring the monitoring of subrecipients
for federal awards on a timely basis. Recipients of federal awards are responsible for monitoring
the activities of subrecipients to ensure that they comply with applicable laws, regulations, and
the terms and conditions of the federal award. CUAHSI did not complete the monitoring of its
2021 subrecipients until 2024. During the year ended December 31, 2021, CUAHSI had
$128,472 in amounts paid to subrecipients. Based on our testing of amounts paid to
subrecipients, no amounts were identified as unallowable.
Cause & Context
CUAHSI had a policy and procedure manual in place which outlined the steps for monitoring.
There was no audit evidence of CUAHSI following the policy and monitoring that the
subrecipient was using the funding as prescribed during the year ended December 31, 2021.
Effect
CUAHSI’s lack of monitoring creates a significant risk of the possible misuse or improper use of
funds.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-005.
Recommendation
The auditor recommends that management review the requirements documented in 31 USC
7502(f)(2), 2 CFR sections 200.330, .331, and .501(h);(Requirements for Pass-Through Entities)
and develops and implements procedures to adhere to such requirements.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
Material Weakness
MW2021-006 CASH MANAGEMENT
Criteria
2 CFR Part 200 states that entities expending federal grants must establish and maintain effective
internal control over the federal award that provides reasonable assurance that the non-federal
entity is managing the federal award in compliance with federal statues, regulations, and the
terms and conditions of the Federal award. To comply with 2 CFR Part 200, CUAHSI was
required to submit monthly invoices for the funds received under the federal contract. These
invoices will serve as a record of the services or goods provided during the specified period and
will facilitate accurate tracking and reporting of the funds. In addition to the invoice, any
supporting documentation, such as timesheets, should be maintained with the invoices. The cash
management process should also be adjusted for the receipt of program income.
These documents validate the services provided and ensure transparency and auditability of the
invoiced amount. These amounts should be able to be traced to the general ledger in conjunction
with the time in which they are billed.
Condition
The cash management process requires that cash draws be reviewed and approved to ensure the
propriety of draw reimbursement requests. Management was unable to provide the auditor
evidence documenting approval of the drawdowns for the year ended December 31, 2021.
Cause & Context
CUAHSI had no fiscal management team during the year ended December 31, 2021 to ensure
compliance with proper policies and procedures. The books and records for the year ended
December 31, 2021 were recreated by the current management team during 2024 to 2025.
Effect
Grant awards and reimbursements may not be recorded correctly and there is a higher risk of
error or misappropriation of assets.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-006.
Recommendation
The auditor recommends CUAHSI develop and implement controls to ensure an adequate review
process is in place for review of reimbursement requests submitted to granting agencies to ensure
consistent reporting.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-007 PROCUREMENT, SUSPENSION AND DEBARMENT
Material Weakness
Criteria
The requirements for this compliance requirement are contained in 2 CFR sections 200.317-
200.326; 48 CFR parts 03, 15, 44, and the clauses at 48 CRF sections 52.244-2, 52.244-5,
52.203-13, 52.203-16 and 52.215-12; agency FAR supplements; 2 CFR part 180; OMB M-18-
18; and the terms and conditions of the federal award. There is a requirement to verify that
contractors in covered transactions or any of its vendors are not federally debarred, suspended, or
excluded.
A covered transaction is a nonprocurement or procurement transaction in excess of $25,000 that
is subject to the prohibitions noted in 2 CFR part 180. The covered transaction may be at the
primary tier, between a federal agency and a person or a lower tier between a participant in a
covered transaction and another person.
Condition
During the completion of the audit, the auditor noted that CUAHSI failed to maintain and
provide the proper records and support to document their review of vendor files for covered
transactions. Such failure led to non-compliance with the procurement, suspension and
debarment policies in accordance with the UG for the year ended December 31, 2021. CUAHSI
did not complete the verification of its 2021 vendors until 2024. Based on our testing, no
contractors in covered transactions were deemed to be federally debarred, suspended or
excluded. Material Weakness
Cause & Context
CUAHSI has a policy in place to meet the procurement requirements but there was no evidence
of compliance with that policy.
Effect
As a result of noncompliance, there could be possible repayment of funds, loss of reputation and
possible suspension or debarment.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-007.
Recommendation
It is recommended that CUAHSI strive to prioritize compliance. CUAHSI should ensure that, to
the extent practicable, the use of a competitive procurement process in compliance with 2 CFR
section 200/317.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-008 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF
EXPENDITURES
Material Weakness
Criteria
CFR § 200.305 Cash management: This section of the CFR outlines the requirements for the
management of cash drawdowns and disbursements of federal funds. Federal funds should be
disbursed in a timely manner for allowable costs that have been incurred. Cash advances must
meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National
Science Foundation.
Condition
CUAHSI did not meet the conditions specified in Chapter VIII.C.3 of the grant agreement with
the National Science Foundation which details the requirements for advance fundings. During
2021, CUAHSI had advance drawdowns totaling $1,172,645 from the NSF. Of this amount,
CUAHSI incurred $1,049,681 in eligible expenses for the year ended December 31, 2021. This
resulted in $122,964 in excess federal advances as of year-end. The draw downs in excess of
revenue recognized during the year ended December 31, 2021 are reported as part of deferred
revenue in the accompanying Statement of Financial Position.
Cause & Context
CUAHSI initiated advance drawdowns without following the guidelines set forth by Chapter
VIII.C.3 of the grant agreement.
Effect
Drawing down funds in advance of incurring eligible expenses could lead to non-compliance
with federal regulations, such as those outlined in 2 CFR § 200.305. This may result in the need
to repay the funds, potential financial penalties, or disqualification from future federal funding.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-008.
Recommendation
The auditor recommends that CUAHSI develops and implements controls over policies
consistent with 2 CFR 200.35.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-009 PROGRAM INCOME
Material Weakness
Criteria
Pursuant to 2 CFR 200 for award objectives and the regulations at 2 CFR 200.307, program
income is defined as “Gross income earned by the recipient that is directly generated by a
supported activity or earned as a result of the federal award during the period of performance” by
2 CFR Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements
for Federal Awards. Program income reporting is due forty five (45) days after the end of the
federal fiscal year. NSF requires that all cumulative program income is reported for all open
grants and agreements in the current year.
Condition
Program income consists of registration fees collected for training, meetings or workshops and
the proceeds from the sale of publications as a result of the federal award during the period of
performance. Program income is treated as an additive to the federal funds received by CUAHSI.
During a drawdown, program income reduces the amount that is requested to cover reimbursable
costs through the Flexible Billing module. This allows program income to be applied to the
award before a reimbursement is requested from NSF adding the value of program income
received to the awarded amount. Program income reporting is due forty five (45) days after the
end of the federal fiscal year. NSF requires that all cumulative program income is reported for all
open grants and agreements in the current year. CUAHSI program income totaled $31,525 for
the year ended December 31, 2021. CUAHSI failed to submit the required Program Income Reporting Worksheet by the required deadline of forty five (45) days after the end of the federal fiscal year (November 15, 2021) to ensure with the program income policies in accordance with the UG for the year ended December 31, 2021.
Cause & Context
Lack of resources and detailed attention to the risks, along with circumvention of controls has
resulted in weak internal controls, and conflicting or incomplete policies and procedures.
Effect
Non-compliance can lead to penalties, fines, or even termination of the contract. It may also
damage CUAHSI’s reputation and future eligibility for federal funding and jeopardize
CUAHSI’s ability to secure future grants or contracts from other funding agencies. Granting
organizations typically prioritize funding recipients with a track record of compliance and
accountability.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-009.
Recommendation
The auditor recommends that CUAHSI develops and implements controls over policies
consistent with 2 CFR 200.307.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation and U.S. Department of Agriculture
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure, Integrative Activities & Forestry Research
AL No.: 47.050, 47.070, 47.079, 47.080, 47.083 & 10.652
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022), OIA-1937099 (09/01/2020
– 08/31/2021) & 19-DG11330140-083 (09/26/2019 – 09/30/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-002 ACCURACY AND COMPLETENESS OF SCHEDULE OF EXPENDITURES OF
FEDERAL AWARDS (“SEFA”)
Material Weakness
Criteria
CUAHSI is required to prepare a SEFA in accordance with the prescribed guidelines of the
Uniform Guidance (“UG”). In addition, 2 CFR Section 200.512(a) of the Uniform Guidance
requires the reporting package and Data Collection Form (“DCF”) to be submitted to the Federal
Audit Clearinghouse the earlier of 30 calendar days after the reports are received from the
auditor or nine months after CUAHSI’s year end.
Condition
CUAHSI provided two different versions of the SEFA to the auditor during the audit process.
Additionally, due to the delay in financial close of CUAHSI’s books and records, a federal single
audit for the year ended December 31, 2021 was not performed in a timely manner and the DCF
was not submitted by its due date of September 30, 2022. The inaccurate reporting of grants and
related activity in the SEFA can lead to improper identification of major programs causing
inadequate testing by the auditor as required by UG. As a result of the audit procedures
performed and proposed adjustments to CUAHSI’s preliminary SEFA by the audit, management
was able to make the required changes.
Cause & Context
Due personnel and staffing issues, CUAHSI was not able to complete the financial close process
in a timely manner which led to the changes in qualified expenditures and delay in the financial
statement and the federal single audit being completed.
Effect
Failure to comply with federal regulations and reporting requirements exposes CUAHSI to
potential legal and regulatory consequences, including the risk of future funding loss and
financial penalties.
Questioned Costs
None
Prior Year Audit Finding
Yes - previously reported as MW2020-002.
Recommendation
To address the identified deficiencies and improve controls over the preparation of the SEFA, the
auditor recommends the development and documentation of procedures for tracking federal
awards and related disbursements to subrecipients.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation and U.S. Department of Agriculture
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure, Integrative Activities & Forestry Research
AL No.: 47.050, 47.070, 47.079, 47.080, 47.083 & 10.652
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022), OIA-1937099 (09/01/2020
– 08/31/2021) & 19-DG11330140-083 (09/26/2019 – 09/30/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-004 REPORTING - DCF
Material Weakness
Criteria
2 CFR Section 200.512(a) requires the reporting package and DCF to be submitted to the Federal
Audit Clearinghouse the earlier of thirty calendar days after the reports are received from the
auditor or nine months after the end of the audit period.
Condition
Due to the delay in financial close of CUAHSI’s books and records, a federal single audit for
fiscal year 2021 was not performed in a timely manner and the DCF was not submitted by its due
date of September 30, 2022. The UG requires the reporting package and DCF to be submitted to
the Federal Audit Clearinghouse the earlier of 30 calendar days after the reports are received
from the auditor (April 2, 2025) or nine months after CUAHSI’s year end (September 30, 2022).
Cause & Context
CUAHSI did not have effective controls in place to allow for a timely year-end closing. This
caused significant auditor delays which resulted in CUAHSI’s inability to meet the filing
requirements under the UG.
Effect
CUAHSI is not in compliance with 2 CFR Part 200, Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-004.
Recommendation
Management should implement policies to ensure timely financial reporting and ensure the
timely completion of an audit.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-005 SUBRECIPIENT MONITORING
Material Weakness
Criteria
The regulations are documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and
.501(h); (Requirements for Pass-Through Entities). The criteria for monitoring subrecipients of
federal awards should be following federal regulations, the terms of the federal contract, and any
additional requirements specified by the auditee's policies and procedures. Specifically, the
monitoring criteria should include, but not be limited to, the following:
• Subrecipient Risk Assessment
• Financial Monitoring
• Compliance Monitoring
• Reporting and Documentation
Condition
The auditee failed to comply with federal regulations requiring the monitoring of subrecipients
for federal awards on a timely basis. Recipients of federal awards are responsible for monitoring
the activities of subrecipients to ensure that they comply with applicable laws, regulations, and
the terms and conditions of the federal award. CUAHSI did not complete the monitoring of its
2021 subrecipients until 2024. During the year ended December 31, 2021, CUAHSI had
$128,472 in amounts paid to subrecipients. Based on our testing of amounts paid to
subrecipients, no amounts were identified as unallowable.
Cause & Context
CUAHSI had a policy and procedure manual in place which outlined the steps for monitoring.
There was no audit evidence of CUAHSI following the policy and monitoring that the
subrecipient was using the funding as prescribed during the year ended December 31, 2021.
Effect
CUAHSI’s lack of monitoring creates a significant risk of the possible misuse or improper use of
funds.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-005.
Recommendation
The auditor recommends that management review the requirements documented in 31 USC
7502(f)(2), 2 CFR sections 200.330, .331, and .501(h);(Requirements for Pass-Through Entities)
and develops and implements procedures to adhere to such requirements.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
Material Weakness
MW2021-006 CASH MANAGEMENT
Criteria
2 CFR Part 200 states that entities expending federal grants must establish and maintain effective
internal control over the federal award that provides reasonable assurance that the non-federal
entity is managing the federal award in compliance with federal statues, regulations, and the
terms and conditions of the Federal award. To comply with 2 CFR Part 200, CUAHSI was
required to submit monthly invoices for the funds received under the federal contract. These
invoices will serve as a record of the services or goods provided during the specified period and
will facilitate accurate tracking and reporting of the funds. In addition to the invoice, any
supporting documentation, such as timesheets, should be maintained with the invoices. The cash
management process should also be adjusted for the receipt of program income.
These documents validate the services provided and ensure transparency and auditability of the
invoiced amount. These amounts should be able to be traced to the general ledger in conjunction
with the time in which they are billed.
Condition
The cash management process requires that cash draws be reviewed and approved to ensure the
propriety of draw reimbursement requests. Management was unable to provide the auditor
evidence documenting approval of the drawdowns for the year ended December 31, 2021.
Cause & Context
CUAHSI had no fiscal management team during the year ended December 31, 2021 to ensure
compliance with proper policies and procedures. The books and records for the year ended
December 31, 2021 were recreated by the current management team during 2024 to 2025.
Effect
Grant awards and reimbursements may not be recorded correctly and there is a higher risk of
error or misappropriation of assets.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-006.
Recommendation
The auditor recommends CUAHSI develop and implement controls to ensure an adequate review
process is in place for review of reimbursement requests submitted to granting agencies to ensure
consistent reporting.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-007 PROCUREMENT, SUSPENSION AND DEBARMENT
Material Weakness
Criteria
The requirements for this compliance requirement are contained in 2 CFR sections 200.317-
200.326; 48 CFR parts 03, 15, 44, and the clauses at 48 CRF sections 52.244-2, 52.244-5,
52.203-13, 52.203-16 and 52.215-12; agency FAR supplements; 2 CFR part 180; OMB M-18-
18; and the terms and conditions of the federal award. There is a requirement to verify that
contractors in covered transactions or any of its vendors are not federally debarred, suspended, or
excluded.
A covered transaction is a nonprocurement or procurement transaction in excess of $25,000 that
is subject to the prohibitions noted in 2 CFR part 180. The covered transaction may be at the
primary tier, between a federal agency and a person or a lower tier between a participant in a
covered transaction and another person.
Condition
During the completion of the audit, the auditor noted that CUAHSI failed to maintain and
provide the proper records and support to document their review of vendor files for covered
transactions. Such failure led to non-compliance with the procurement, suspension and
debarment policies in accordance with the UG for the year ended December 31, 2021. CUAHSI
did not complete the verification of its 2021 vendors until 2024. Based on our testing, no
contractors in covered transactions were deemed to be federally debarred, suspended or
excluded. Material Weakness
Cause & Context
CUAHSI has a policy in place to meet the procurement requirements but there was no evidence
of compliance with that policy.
Effect
As a result of noncompliance, there could be possible repayment of funds, loss of reputation and
possible suspension or debarment.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-007.
Recommendation
It is recommended that CUAHSI strive to prioritize compliance. CUAHSI should ensure that, to
the extent practicable, the use of a competitive procurement process in compliance with 2 CFR
section 200/317.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-008 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF
EXPENDITURES
Material Weakness
Criteria
CFR § 200.305 Cash management: This section of the CFR outlines the requirements for the
management of cash drawdowns and disbursements of federal funds. Federal funds should be
disbursed in a timely manner for allowable costs that have been incurred. Cash advances must
meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National
Science Foundation.
Condition
CUAHSI did not meet the conditions specified in Chapter VIII.C.3 of the grant agreement with
the National Science Foundation which details the requirements for advance fundings. During
2021, CUAHSI had advance drawdowns totaling $1,172,645 from the NSF. Of this amount,
CUAHSI incurred $1,049,681 in eligible expenses for the year ended December 31, 2021. This
resulted in $122,964 in excess federal advances as of year-end. The draw downs in excess of
revenue recognized during the year ended December 31, 2021 are reported as part of deferred
revenue in the accompanying Statement of Financial Position.
Cause & Context
CUAHSI initiated advance drawdowns without following the guidelines set forth by Chapter
VIII.C.3 of the grant agreement.
Effect
Drawing down funds in advance of incurring eligible expenses could lead to non-compliance
with federal regulations, such as those outlined in 2 CFR § 200.305. This may result in the need
to repay the funds, potential financial penalties, or disqualification from future federal funding.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-008.
Recommendation
The auditor recommends that CUAHSI develops and implements controls over policies
consistent with 2 CFR 200.35.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-009 PROGRAM INCOME
Material Weakness
Criteria
Pursuant to 2 CFR 200 for award objectives and the regulations at 2 CFR 200.307, program
income is defined as “Gross income earned by the recipient that is directly generated by a
supported activity or earned as a result of the federal award during the period of performance” by
2 CFR Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements
for Federal Awards. Program income reporting is due forty five (45) days after the end of the
federal fiscal year. NSF requires that all cumulative program income is reported for all open
grants and agreements in the current year.
Condition
Program income consists of registration fees collected for training, meetings or workshops and
the proceeds from the sale of publications as a result of the federal award during the period of
performance. Program income is treated as an additive to the federal funds received by CUAHSI.
During a drawdown, program income reduces the amount that is requested to cover reimbursable
costs through the Flexible Billing module. This allows program income to be applied to the
award before a reimbursement is requested from NSF adding the value of program income
received to the awarded amount. Program income reporting is due forty five (45) days after the
end of the federal fiscal year. NSF requires that all cumulative program income is reported for all
open grants and agreements in the current year. CUAHSI program income totaled $31,525 for
the year ended December 31, 2021. CUAHSI failed to submit the required Program Income Reporting Worksheet by the required deadline of forty five (45) days after the end of the federal fiscal year (November 15, 2021) to ensure with the program income policies in accordance with the UG for the year ended December 31, 2021.
Cause & Context
Lack of resources and detailed attention to the risks, along with circumvention of controls has
resulted in weak internal controls, and conflicting or incomplete policies and procedures.
Effect
Non-compliance can lead to penalties, fines, or even termination of the contract. It may also
damage CUAHSI’s reputation and future eligibility for federal funding and jeopardize
CUAHSI’s ability to secure future grants or contracts from other funding agencies. Granting
organizations typically prioritize funding recipients with a track record of compliance and
accountability.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-009.
Recommendation
The auditor recommends that CUAHSI develops and implements controls over policies
consistent with 2 CFR 200.307.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation and U.S. Department of Agriculture
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure, Integrative Activities & Forestry Research
AL No.: 47.050, 47.070, 47.079, 47.080, 47.083 & 10.652
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022), OIA-1937099 (09/01/2020
– 08/31/2021) & 19-DG11330140-083 (09/26/2019 – 09/30/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-002 ACCURACY AND COMPLETENESS OF SCHEDULE OF EXPENDITURES OF
FEDERAL AWARDS (“SEFA”)
Material Weakness
Criteria
CUAHSI is required to prepare a SEFA in accordance with the prescribed guidelines of the
Uniform Guidance (“UG”). In addition, 2 CFR Section 200.512(a) of the Uniform Guidance
requires the reporting package and Data Collection Form (“DCF”) to be submitted to the Federal
Audit Clearinghouse the earlier of 30 calendar days after the reports are received from the
auditor or nine months after CUAHSI’s year end.
Condition
CUAHSI provided two different versions of the SEFA to the auditor during the audit process.
Additionally, due to the delay in financial close of CUAHSI’s books and records, a federal single
audit for the year ended December 31, 2021 was not performed in a timely manner and the DCF
was not submitted by its due date of September 30, 2022. The inaccurate reporting of grants and
related activity in the SEFA can lead to improper identification of major programs causing
inadequate testing by the auditor as required by UG. As a result of the audit procedures
performed and proposed adjustments to CUAHSI’s preliminary SEFA by the audit, management
was able to make the required changes.
Cause & Context
Due personnel and staffing issues, CUAHSI was not able to complete the financial close process
in a timely manner which led to the changes in qualified expenditures and delay in the financial
statement and the federal single audit being completed.
Effect
Failure to comply with federal regulations and reporting requirements exposes CUAHSI to
potential legal and regulatory consequences, including the risk of future funding loss and
financial penalties.
Questioned Costs
None
Prior Year Audit Finding
Yes - previously reported as MW2020-002.
Recommendation
To address the identified deficiencies and improve controls over the preparation of the SEFA, the
auditor recommends the development and documentation of procedures for tracking federal
awards and related disbursements to subrecipients.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation and U.S. Department of Agriculture
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure, Integrative Activities & Forestry Research
AL No.: 47.050, 47.070, 47.079, 47.080, 47.083 & 10.652
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022), OIA-1937099 (09/01/2020
– 08/31/2021) & 19-DG11330140-083 (09/26/2019 – 09/30/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-004 REPORTING - DCF
Material Weakness
Criteria
2 CFR Section 200.512(a) requires the reporting package and DCF to be submitted to the Federal
Audit Clearinghouse the earlier of thirty calendar days after the reports are received from the
auditor or nine months after the end of the audit period.
Condition
Due to the delay in financial close of CUAHSI’s books and records, a federal single audit for
fiscal year 2021 was not performed in a timely manner and the DCF was not submitted by its due
date of September 30, 2022. The UG requires the reporting package and DCF to be submitted to
the Federal Audit Clearinghouse the earlier of 30 calendar days after the reports are received
from the auditor (April 2, 2025) or nine months after CUAHSI’s year end (September 30, 2022).
Cause & Context
CUAHSI did not have effective controls in place to allow for a timely year-end closing. This
caused significant auditor delays which resulted in CUAHSI’s inability to meet the filing
requirements under the UG.
Effect
CUAHSI is not in compliance with 2 CFR Part 200, Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-004.
Recommendation
Management should implement policies to ensure timely financial reporting and ensure the
timely completion of an audit.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-005 SUBRECIPIENT MONITORING
Material Weakness
Criteria
The regulations are documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and
.501(h); (Requirements for Pass-Through Entities). The criteria for monitoring subrecipients of
federal awards should be following federal regulations, the terms of the federal contract, and any
additional requirements specified by the auditee's policies and procedures. Specifically, the
monitoring criteria should include, but not be limited to, the following:
• Subrecipient Risk Assessment
• Financial Monitoring
• Compliance Monitoring
• Reporting and Documentation
Condition
The auditee failed to comply with federal regulations requiring the monitoring of subrecipients
for federal awards on a timely basis. Recipients of federal awards are responsible for monitoring
the activities of subrecipients to ensure that they comply with applicable laws, regulations, and
the terms and conditions of the federal award. CUAHSI did not complete the monitoring of its
2021 subrecipients until 2024. During the year ended December 31, 2021, CUAHSI had
$128,472 in amounts paid to subrecipients. Based on our testing of amounts paid to
subrecipients, no amounts were identified as unallowable.
Cause & Context
CUAHSI had a policy and procedure manual in place which outlined the steps for monitoring.
There was no audit evidence of CUAHSI following the policy and monitoring that the
subrecipient was using the funding as prescribed during the year ended December 31, 2021.
Effect
CUAHSI’s lack of monitoring creates a significant risk of the possible misuse or improper use of
funds.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-005.
Recommendation
The auditor recommends that management review the requirements documented in 31 USC
7502(f)(2), 2 CFR sections 200.330, .331, and .501(h);(Requirements for Pass-Through Entities)
and develops and implements procedures to adhere to such requirements.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
Material Weakness
MW2021-006 CASH MANAGEMENT
Criteria
2 CFR Part 200 states that entities expending federal grants must establish and maintain effective
internal control over the federal award that provides reasonable assurance that the non-federal
entity is managing the federal award in compliance with federal statues, regulations, and the
terms and conditions of the Federal award. To comply with 2 CFR Part 200, CUAHSI was
required to submit monthly invoices for the funds received under the federal contract. These
invoices will serve as a record of the services or goods provided during the specified period and
will facilitate accurate tracking and reporting of the funds. In addition to the invoice, any
supporting documentation, such as timesheets, should be maintained with the invoices. The cash
management process should also be adjusted for the receipt of program income.
These documents validate the services provided and ensure transparency and auditability of the
invoiced amount. These amounts should be able to be traced to the general ledger in conjunction
with the time in which they are billed.
Condition
The cash management process requires that cash draws be reviewed and approved to ensure the
propriety of draw reimbursement requests. Management was unable to provide the auditor
evidence documenting approval of the drawdowns for the year ended December 31, 2021.
Cause & Context
CUAHSI had no fiscal management team during the year ended December 31, 2021 to ensure
compliance with proper policies and procedures. The books and records for the year ended
December 31, 2021 were recreated by the current management team during 2024 to 2025.
Effect
Grant awards and reimbursements may not be recorded correctly and there is a higher risk of
error or misappropriation of assets.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-006.
Recommendation
The auditor recommends CUAHSI develop and implement controls to ensure an adequate review
process is in place for review of reimbursement requests submitted to granting agencies to ensure
consistent reporting.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-007 PROCUREMENT, SUSPENSION AND DEBARMENT
Material Weakness
Criteria
The requirements for this compliance requirement are contained in 2 CFR sections 200.317-
200.326; 48 CFR parts 03, 15, 44, and the clauses at 48 CRF sections 52.244-2, 52.244-5,
52.203-13, 52.203-16 and 52.215-12; agency FAR supplements; 2 CFR part 180; OMB M-18-
18; and the terms and conditions of the federal award. There is a requirement to verify that
contractors in covered transactions or any of its vendors are not federally debarred, suspended, or
excluded.
A covered transaction is a nonprocurement or procurement transaction in excess of $25,000 that
is subject to the prohibitions noted in 2 CFR part 180. The covered transaction may be at the
primary tier, between a federal agency and a person or a lower tier between a participant in a
covered transaction and another person.
Condition
During the completion of the audit, the auditor noted that CUAHSI failed to maintain and
provide the proper records and support to document their review of vendor files for covered
transactions. Such failure led to non-compliance with the procurement, suspension and
debarment policies in accordance with the UG for the year ended December 31, 2021. CUAHSI
did not complete the verification of its 2021 vendors until 2024. Based on our testing, no
contractors in covered transactions were deemed to be federally debarred, suspended or
excluded. Material Weakness
Cause & Context
CUAHSI has a policy in place to meet the procurement requirements but there was no evidence
of compliance with that policy.
Effect
As a result of noncompliance, there could be possible repayment of funds, loss of reputation and
possible suspension or debarment.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-007.
Recommendation
It is recommended that CUAHSI strive to prioritize compliance. CUAHSI should ensure that, to
the extent practicable, the use of a competitive procurement process in compliance with 2 CFR
section 200/317.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-008 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF
EXPENDITURES
Material Weakness
Criteria
CFR § 200.305 Cash management: This section of the CFR outlines the requirements for the
management of cash drawdowns and disbursements of federal funds. Federal funds should be
disbursed in a timely manner for allowable costs that have been incurred. Cash advances must
meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National
Science Foundation.
Condition
CUAHSI did not meet the conditions specified in Chapter VIII.C.3 of the grant agreement with
the National Science Foundation which details the requirements for advance fundings. During
2021, CUAHSI had advance drawdowns totaling $1,172,645 from the NSF. Of this amount,
CUAHSI incurred $1,049,681 in eligible expenses for the year ended December 31, 2021. This
resulted in $122,964 in excess federal advances as of year-end. The draw downs in excess of
revenue recognized during the year ended December 31, 2021 are reported as part of deferred
revenue in the accompanying Statement of Financial Position.
Cause & Context
CUAHSI initiated advance drawdowns without following the guidelines set forth by Chapter
VIII.C.3 of the grant agreement.
Effect
Drawing down funds in advance of incurring eligible expenses could lead to non-compliance
with federal regulations, such as those outlined in 2 CFR § 200.305. This may result in the need
to repay the funds, potential financial penalties, or disqualification from future federal funding.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-008.
Recommendation
The auditor recommends that CUAHSI develops and implements controls over policies
consistent with 2 CFR 200.35.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-009 PROGRAM INCOME
Material Weakness
Criteria
Pursuant to 2 CFR 200 for award objectives and the regulations at 2 CFR 200.307, program
income is defined as “Gross income earned by the recipient that is directly generated by a
supported activity or earned as a result of the federal award during the period of performance” by
2 CFR Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements
for Federal Awards. Program income reporting is due forty five (45) days after the end of the
federal fiscal year. NSF requires that all cumulative program income is reported for all open
grants and agreements in the current year.
Condition
Program income consists of registration fees collected for training, meetings or workshops and
the proceeds from the sale of publications as a result of the federal award during the period of
performance. Program income is treated as an additive to the federal funds received by CUAHSI.
During a drawdown, program income reduces the amount that is requested to cover reimbursable
costs through the Flexible Billing module. This allows program income to be applied to the
award before a reimbursement is requested from NSF adding the value of program income
received to the awarded amount. Program income reporting is due forty five (45) days after the
end of the federal fiscal year. NSF requires that all cumulative program income is reported for all
open grants and agreements in the current year. CUAHSI program income totaled $31,525 for
the year ended December 31, 2021. CUAHSI failed to submit the required Program Income Reporting Worksheet by the required deadline of forty five (45) days after the end of the federal fiscal year (November 15, 2021) to ensure with the program income policies in accordance with the UG for the year ended December 31, 2021.
Cause & Context
Lack of resources and detailed attention to the risks, along with circumvention of controls has
resulted in weak internal controls, and conflicting or incomplete policies and procedures.
Effect
Non-compliance can lead to penalties, fines, or even termination of the contract. It may also
damage CUAHSI’s reputation and future eligibility for federal funding and jeopardize
CUAHSI’s ability to secure future grants or contracts from other funding agencies. Granting
organizations typically prioritize funding recipients with a track record of compliance and
accountability.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-009.
Recommendation
The auditor recommends that CUAHSI develops and implements controls over policies
consistent with 2 CFR 200.307.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation and U.S. Department of Agriculture
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure, Integrative Activities & Forestry Research
AL No.: 47.050, 47.070, 47.079, 47.080, 47.083 & 10.652
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022), OIA-1937099 (09/01/2020
– 08/31/2021) & 19-DG11330140-083 (09/26/2019 – 09/30/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-002 ACCURACY AND COMPLETENESS OF SCHEDULE OF EXPENDITURES OF
FEDERAL AWARDS (“SEFA”)
Material Weakness
Criteria
CUAHSI is required to prepare a SEFA in accordance with the prescribed guidelines of the
Uniform Guidance (“UG”). In addition, 2 CFR Section 200.512(a) of the Uniform Guidance
requires the reporting package and Data Collection Form (“DCF”) to be submitted to the Federal
Audit Clearinghouse the earlier of 30 calendar days after the reports are received from the
auditor or nine months after CUAHSI’s year end.
Condition
CUAHSI provided two different versions of the SEFA to the auditor during the audit process.
Additionally, due to the delay in financial close of CUAHSI’s books and records, a federal single
audit for the year ended December 31, 2021 was not performed in a timely manner and the DCF
was not submitted by its due date of September 30, 2022. The inaccurate reporting of grants and
related activity in the SEFA can lead to improper identification of major programs causing
inadequate testing by the auditor as required by UG. As a result of the audit procedures
performed and proposed adjustments to CUAHSI’s preliminary SEFA by the audit, management
was able to make the required changes.
Cause & Context
Due personnel and staffing issues, CUAHSI was not able to complete the financial close process
in a timely manner which led to the changes in qualified expenditures and delay in the financial
statement and the federal single audit being completed.
Effect
Failure to comply with federal regulations and reporting requirements exposes CUAHSI to
potential legal and regulatory consequences, including the risk of future funding loss and
financial penalties.
Questioned Costs
None
Prior Year Audit Finding
Yes - previously reported as MW2020-002.
Recommendation
To address the identified deficiencies and improve controls over the preparation of the SEFA, the
auditor recommends the development and documentation of procedures for tracking federal
awards and related disbursements to subrecipients.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation and U.S. Department of Agriculture
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure, Integrative Activities & Forestry Research
AL No.: 47.050, 47.070, 47.079, 47.080, 47.083 & 10.652
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022), OIA-1937099 (09/01/2020
– 08/31/2021) & 19-DG11330140-083 (09/26/2019 – 09/30/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-004 REPORTING - DCF
Material Weakness
Criteria
2 CFR Section 200.512(a) requires the reporting package and DCF to be submitted to the Federal
Audit Clearinghouse the earlier of thirty calendar days after the reports are received from the
auditor or nine months after the end of the audit period.
Condition
Due to the delay in financial close of CUAHSI’s books and records, a federal single audit for
fiscal year 2021 was not performed in a timely manner and the DCF was not submitted by its due
date of September 30, 2022. The UG requires the reporting package and DCF to be submitted to
the Federal Audit Clearinghouse the earlier of 30 calendar days after the reports are received
from the auditor (April 2, 2025) or nine months after CUAHSI’s year end (September 30, 2022).
Cause & Context
CUAHSI did not have effective controls in place to allow for a timely year-end closing. This
caused significant auditor delays which resulted in CUAHSI’s inability to meet the filing
requirements under the UG.
Effect
CUAHSI is not in compliance with 2 CFR Part 200, Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-004.
Recommendation
Management should implement policies to ensure timely financial reporting and ensure the
timely completion of an audit.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-005 SUBRECIPIENT MONITORING
Material Weakness
Criteria
The regulations are documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and
.501(h); (Requirements for Pass-Through Entities). The criteria for monitoring subrecipients of
federal awards should be following federal regulations, the terms of the federal contract, and any
additional requirements specified by the auditee's policies and procedures. Specifically, the
monitoring criteria should include, but not be limited to, the following:
• Subrecipient Risk Assessment
• Financial Monitoring
• Compliance Monitoring
• Reporting and Documentation
Condition
The auditee failed to comply with federal regulations requiring the monitoring of subrecipients
for federal awards on a timely basis. Recipients of federal awards are responsible for monitoring
the activities of subrecipients to ensure that they comply with applicable laws, regulations, and
the terms and conditions of the federal award. CUAHSI did not complete the monitoring of its
2021 subrecipients until 2024. During the year ended December 31, 2021, CUAHSI had
$128,472 in amounts paid to subrecipients. Based on our testing of amounts paid to
subrecipients, no amounts were identified as unallowable.
Cause & Context
CUAHSI had a policy and procedure manual in place which outlined the steps for monitoring.
There was no audit evidence of CUAHSI following the policy and monitoring that the
subrecipient was using the funding as prescribed during the year ended December 31, 2021.
Effect
CUAHSI’s lack of monitoring creates a significant risk of the possible misuse or improper use of
funds.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-005.
Recommendation
The auditor recommends that management review the requirements documented in 31 USC
7502(f)(2), 2 CFR sections 200.330, .331, and .501(h);(Requirements for Pass-Through Entities)
and develops and implements procedures to adhere to such requirements.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
Material Weakness
MW2021-006 CASH MANAGEMENT
Criteria
2 CFR Part 200 states that entities expending federal grants must establish and maintain effective
internal control over the federal award that provides reasonable assurance that the non-federal
entity is managing the federal award in compliance with federal statues, regulations, and the
terms and conditions of the Federal award. To comply with 2 CFR Part 200, CUAHSI was
required to submit monthly invoices for the funds received under the federal contract. These
invoices will serve as a record of the services or goods provided during the specified period and
will facilitate accurate tracking and reporting of the funds. In addition to the invoice, any
supporting documentation, such as timesheets, should be maintained with the invoices. The cash
management process should also be adjusted for the receipt of program income.
These documents validate the services provided and ensure transparency and auditability of the
invoiced amount. These amounts should be able to be traced to the general ledger in conjunction
with the time in which they are billed.
Condition
The cash management process requires that cash draws be reviewed and approved to ensure the
propriety of draw reimbursement requests. Management was unable to provide the auditor
evidence documenting approval of the drawdowns for the year ended December 31, 2021.
Cause & Context
CUAHSI had no fiscal management team during the year ended December 31, 2021 to ensure
compliance with proper policies and procedures. The books and records for the year ended
December 31, 2021 were recreated by the current management team during 2024 to 2025.
Effect
Grant awards and reimbursements may not be recorded correctly and there is a higher risk of
error or misappropriation of assets.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-006.
Recommendation
The auditor recommends CUAHSI develop and implement controls to ensure an adequate review
process is in place for review of reimbursement requests submitted to granting agencies to ensure
consistent reporting.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-007 PROCUREMENT, SUSPENSION AND DEBARMENT
Material Weakness
Criteria
The requirements for this compliance requirement are contained in 2 CFR sections 200.317-
200.326; 48 CFR parts 03, 15, 44, and the clauses at 48 CRF sections 52.244-2, 52.244-5,
52.203-13, 52.203-16 and 52.215-12; agency FAR supplements; 2 CFR part 180; OMB M-18-
18; and the terms and conditions of the federal award. There is a requirement to verify that
contractors in covered transactions or any of its vendors are not federally debarred, suspended, or
excluded.
A covered transaction is a nonprocurement or procurement transaction in excess of $25,000 that
is subject to the prohibitions noted in 2 CFR part 180. The covered transaction may be at the
primary tier, between a federal agency and a person or a lower tier between a participant in a
covered transaction and another person.
Condition
During the completion of the audit, the auditor noted that CUAHSI failed to maintain and
provide the proper records and support to document their review of vendor files for covered
transactions. Such failure led to non-compliance with the procurement, suspension and
debarment policies in accordance with the UG for the year ended December 31, 2021. CUAHSI
did not complete the verification of its 2021 vendors until 2024. Based on our testing, no
contractors in covered transactions were deemed to be federally debarred, suspended or
excluded. Material Weakness
Cause & Context
CUAHSI has a policy in place to meet the procurement requirements but there was no evidence
of compliance with that policy.
Effect
As a result of noncompliance, there could be possible repayment of funds, loss of reputation and
possible suspension or debarment.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-007.
Recommendation
It is recommended that CUAHSI strive to prioritize compliance. CUAHSI should ensure that, to
the extent practicable, the use of a competitive procurement process in compliance with 2 CFR
section 200/317.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-008 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF
EXPENDITURES
Material Weakness
Criteria
CFR § 200.305 Cash management: This section of the CFR outlines the requirements for the
management of cash drawdowns and disbursements of federal funds. Federal funds should be
disbursed in a timely manner for allowable costs that have been incurred. Cash advances must
meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National
Science Foundation.
Condition
CUAHSI did not meet the conditions specified in Chapter VIII.C.3 of the grant agreement with
the National Science Foundation which details the requirements for advance fundings. During
2021, CUAHSI had advance drawdowns totaling $1,172,645 from the NSF. Of this amount,
CUAHSI incurred $1,049,681 in eligible expenses for the year ended December 31, 2021. This
resulted in $122,964 in excess federal advances as of year-end. The draw downs in excess of
revenue recognized during the year ended December 31, 2021 are reported as part of deferred
revenue in the accompanying Statement of Financial Position.
Cause & Context
CUAHSI initiated advance drawdowns without following the guidelines set forth by Chapter
VIII.C.3 of the grant agreement.
Effect
Drawing down funds in advance of incurring eligible expenses could lead to non-compliance
with federal regulations, such as those outlined in 2 CFR § 200.305. This may result in the need
to repay the funds, potential financial penalties, or disqualification from future federal funding.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-008.
Recommendation
The auditor recommends that CUAHSI develops and implements controls over policies
consistent with 2 CFR 200.35.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-009 PROGRAM INCOME
Material Weakness
Criteria
Pursuant to 2 CFR 200 for award objectives and the regulations at 2 CFR 200.307, program
income is defined as “Gross income earned by the recipient that is directly generated by a
supported activity or earned as a result of the federal award during the period of performance” by
2 CFR Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements
for Federal Awards. Program income reporting is due forty five (45) days after the end of the
federal fiscal year. NSF requires that all cumulative program income is reported for all open
grants and agreements in the current year.
Condition
Program income consists of registration fees collected for training, meetings or workshops and
the proceeds from the sale of publications as a result of the federal award during the period of
performance. Program income is treated as an additive to the federal funds received by CUAHSI.
During a drawdown, program income reduces the amount that is requested to cover reimbursable
costs through the Flexible Billing module. This allows program income to be applied to the
award before a reimbursement is requested from NSF adding the value of program income
received to the awarded amount. Program income reporting is due forty five (45) days after the
end of the federal fiscal year. NSF requires that all cumulative program income is reported for all
open grants and agreements in the current year. CUAHSI program income totaled $31,525 for
the year ended December 31, 2021. CUAHSI failed to submit the required Program Income Reporting Worksheet by the required deadline of forty five (45) days after the end of the federal fiscal year (November 15, 2021) to ensure with the program income policies in accordance with the UG for the year ended December 31, 2021.
Cause & Context
Lack of resources and detailed attention to the risks, along with circumvention of controls has
resulted in weak internal controls, and conflicting or incomplete policies and procedures.
Effect
Non-compliance can lead to penalties, fines, or even termination of the contract. It may also
damage CUAHSI’s reputation and future eligibility for federal funding and jeopardize
CUAHSI’s ability to secure future grants or contracts from other funding agencies. Granting
organizations typically prioritize funding recipients with a track record of compliance and
accountability.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-009.
Recommendation
The auditor recommends that CUAHSI develops and implements controls over policies
consistent with 2 CFR 200.307.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation and U.S. Department of Agriculture
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure, Integrative Activities & Forestry Research
AL No.: 47.050, 47.070, 47.079, 47.080, 47.083 & 10.652
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022), OIA-1937099 (09/01/2020
– 08/31/2021) & 19-DG11330140-083 (09/26/2019 – 09/30/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-002 ACCURACY AND COMPLETENESS OF SCHEDULE OF EXPENDITURES OF
FEDERAL AWARDS (“SEFA”)
Material Weakness
Criteria
CUAHSI is required to prepare a SEFA in accordance with the prescribed guidelines of the
Uniform Guidance (“UG”). In addition, 2 CFR Section 200.512(a) of the Uniform Guidance
requires the reporting package and Data Collection Form (“DCF”) to be submitted to the Federal
Audit Clearinghouse the earlier of 30 calendar days after the reports are received from the
auditor or nine months after CUAHSI’s year end.
Condition
CUAHSI provided two different versions of the SEFA to the auditor during the audit process.
Additionally, due to the delay in financial close of CUAHSI’s books and records, a federal single
audit for the year ended December 31, 2021 was not performed in a timely manner and the DCF
was not submitted by its due date of September 30, 2022. The inaccurate reporting of grants and
related activity in the SEFA can lead to improper identification of major programs causing
inadequate testing by the auditor as required by UG. As a result of the audit procedures
performed and proposed adjustments to CUAHSI’s preliminary SEFA by the audit, management
was able to make the required changes.
Cause & Context
Due personnel and staffing issues, CUAHSI was not able to complete the financial close process
in a timely manner which led to the changes in qualified expenditures and delay in the financial
statement and the federal single audit being completed.
Effect
Failure to comply with federal regulations and reporting requirements exposes CUAHSI to
potential legal and regulatory consequences, including the risk of future funding loss and
financial penalties.
Questioned Costs
None
Prior Year Audit Finding
Yes - previously reported as MW2020-002.
Recommendation
To address the identified deficiencies and improve controls over the preparation of the SEFA, the
auditor recommends the development and documentation of procedures for tracking federal
awards and related disbursements to subrecipients.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation and U.S. Department of Agriculture
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure, Integrative Activities & Forestry Research
AL No.: 47.050, 47.070, 47.079, 47.080, 47.083 & 10.652
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022), OIA-1937099 (09/01/2020
– 08/31/2021) & 19-DG11330140-083 (09/26/2019 – 09/30/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-004 REPORTING - DCF
Material Weakness
Criteria
2 CFR Section 200.512(a) requires the reporting package and DCF to be submitted to the Federal
Audit Clearinghouse the earlier of thirty calendar days after the reports are received from the
auditor or nine months after the end of the audit period.
Condition
Due to the delay in financial close of CUAHSI’s books and records, a federal single audit for
fiscal year 2021 was not performed in a timely manner and the DCF was not submitted by its due
date of September 30, 2022. The UG requires the reporting package and DCF to be submitted to
the Federal Audit Clearinghouse the earlier of 30 calendar days after the reports are received
from the auditor (April 2, 2025) or nine months after CUAHSI’s year end (September 30, 2022).
Cause & Context
CUAHSI did not have effective controls in place to allow for a timely year-end closing. This
caused significant auditor delays which resulted in CUAHSI’s inability to meet the filing
requirements under the UG.
Effect
CUAHSI is not in compliance with 2 CFR Part 200, Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-004.
Recommendation
Management should implement policies to ensure timely financial reporting and ensure the
timely completion of an audit.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-005 SUBRECIPIENT MONITORING
Material Weakness
Criteria
The regulations are documented in 31 USC 7502(f)(2), 2 CFR sections 200.330, .331, and
.501(h); (Requirements for Pass-Through Entities). The criteria for monitoring subrecipients of
federal awards should be following federal regulations, the terms of the federal contract, and any
additional requirements specified by the auditee's policies and procedures. Specifically, the
monitoring criteria should include, but not be limited to, the following:
• Subrecipient Risk Assessment
• Financial Monitoring
• Compliance Monitoring
• Reporting and Documentation
Condition
The auditee failed to comply with federal regulations requiring the monitoring of subrecipients
for federal awards on a timely basis. Recipients of federal awards are responsible for monitoring
the activities of subrecipients to ensure that they comply with applicable laws, regulations, and
the terms and conditions of the federal award. CUAHSI did not complete the monitoring of its
2021 subrecipients until 2024. During the year ended December 31, 2021, CUAHSI had
$128,472 in amounts paid to subrecipients. Based on our testing of amounts paid to
subrecipients, no amounts were identified as unallowable.
Cause & Context
CUAHSI had a policy and procedure manual in place which outlined the steps for monitoring.
There was no audit evidence of CUAHSI following the policy and monitoring that the
subrecipient was using the funding as prescribed during the year ended December 31, 2021.
Effect
CUAHSI’s lack of monitoring creates a significant risk of the possible misuse or improper use of
funds.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-005.
Recommendation
The auditor recommends that management review the requirements documented in 31 USC
7502(f)(2), 2 CFR sections 200.330, .331, and .501(h);(Requirements for Pass-Through Entities)
and develops and implements procedures to adhere to such requirements.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
Material Weakness
MW2021-006 CASH MANAGEMENT
Criteria
2 CFR Part 200 states that entities expending federal grants must establish and maintain effective
internal control over the federal award that provides reasonable assurance that the non-federal
entity is managing the federal award in compliance with federal statues, regulations, and the
terms and conditions of the Federal award. To comply with 2 CFR Part 200, CUAHSI was
required to submit monthly invoices for the funds received under the federal contract. These
invoices will serve as a record of the services or goods provided during the specified period and
will facilitate accurate tracking and reporting of the funds. In addition to the invoice, any
supporting documentation, such as timesheets, should be maintained with the invoices. The cash
management process should also be adjusted for the receipt of program income.
These documents validate the services provided and ensure transparency and auditability of the
invoiced amount. These amounts should be able to be traced to the general ledger in conjunction
with the time in which they are billed.
Condition
The cash management process requires that cash draws be reviewed and approved to ensure the
propriety of draw reimbursement requests. Management was unable to provide the auditor
evidence documenting approval of the drawdowns for the year ended December 31, 2021.
Cause & Context
CUAHSI had no fiscal management team during the year ended December 31, 2021 to ensure
compliance with proper policies and procedures. The books and records for the year ended
December 31, 2021 were recreated by the current management team during 2024 to 2025.
Effect
Grant awards and reimbursements may not be recorded correctly and there is a higher risk of
error or misappropriation of assets.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-006.
Recommendation
The auditor recommends CUAHSI develop and implement controls to ensure an adequate review
process is in place for review of reimbursement requests submitted to granting agencies to ensure
consistent reporting.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-007 PROCUREMENT, SUSPENSION AND DEBARMENT
Material Weakness
Criteria
The requirements for this compliance requirement are contained in 2 CFR sections 200.317-
200.326; 48 CFR parts 03, 15, 44, and the clauses at 48 CRF sections 52.244-2, 52.244-5,
52.203-13, 52.203-16 and 52.215-12; agency FAR supplements; 2 CFR part 180; OMB M-18-
18; and the terms and conditions of the federal award. There is a requirement to verify that
contractors in covered transactions or any of its vendors are not federally debarred, suspended, or
excluded.
A covered transaction is a nonprocurement or procurement transaction in excess of $25,000 that
is subject to the prohibitions noted in 2 CFR part 180. The covered transaction may be at the
primary tier, between a federal agency and a person or a lower tier between a participant in a
covered transaction and another person.
Condition
During the completion of the audit, the auditor noted that CUAHSI failed to maintain and
provide the proper records and support to document their review of vendor files for covered
transactions. Such failure led to non-compliance with the procurement, suspension and
debarment policies in accordance with the UG for the year ended December 31, 2021. CUAHSI
did not complete the verification of its 2021 vendors until 2024. Based on our testing, no
contractors in covered transactions were deemed to be federally debarred, suspended or
excluded. Material Weakness
Cause & Context
CUAHSI has a policy in place to meet the procurement requirements but there was no evidence
of compliance with that policy.
Effect
As a result of noncompliance, there could be possible repayment of funds, loss of reputation and
possible suspension or debarment.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-007.
Recommendation
It is recommended that CUAHSI strive to prioritize compliance. CUAHSI should ensure that, to
the extent practicable, the use of a competitive procurement process in compliance with 2 CFR
section 200/317.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-008 CASH MANAGEMENT - FEDERAL DRAWDOWNS IN ADVANCE OF
EXPENDITURES
Material Weakness
Criteria
CFR § 200.305 Cash management: This section of the CFR outlines the requirements for the
management of cash drawdowns and disbursements of federal funds. Federal funds should be
disbursed in a timely manner for allowable costs that have been incurred. Cash advances must
meet the conditions specified in Chapter VIII.C.3 of the grant agreement with the National
Science Foundation.
Condition
CUAHSI did not meet the conditions specified in Chapter VIII.C.3 of the grant agreement with
the National Science Foundation which details the requirements for advance fundings. During
2021, CUAHSI had advance drawdowns totaling $1,172,645 from the NSF. Of this amount,
CUAHSI incurred $1,049,681 in eligible expenses for the year ended December 31, 2021. This
resulted in $122,964 in excess federal advances as of year-end. The draw downs in excess of
revenue recognized during the year ended December 31, 2021 are reported as part of deferred
revenue in the accompanying Statement of Financial Position.
Cause & Context
CUAHSI initiated advance drawdowns without following the guidelines set forth by Chapter
VIII.C.3 of the grant agreement.
Effect
Drawing down funds in advance of incurring eligible expenses could lead to non-compliance
with federal regulations, such as those outlined in 2 CFR § 200.305. This may result in the need
to repay the funds, potential financial penalties, or disqualification from future federal funding.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-008.
Recommendation
The auditor recommends that CUAHSI develops and implements controls over policies
consistent with 2 CFR 200.35.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation
Federal program title: Geosciences, Computer and Information Science and Engineering,
Office of Cyber Infrastructure & Integrative Activities
AL No.: 47.050, 47.070, 47.079, 47.080 & 47.083
Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019-05/31/2024),
EAR-2012893 (10/01/2020 – 08/31/2025), EAR-2028793 (05/15/2020 – 04/30/2021), OAC-
1931278 (10/1/2019 – 09/30/2022), OAC-1829744 (09/01/2018 – 08/31/2023), OAC-1835592
(01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OISE-1855654
(05/15/2019 – 12/31/2023), OAC-1664061 (10/01/17 – 09/30/2022) & OIA-1937099
(09/01/2020 – 08/31/2021)
Pass Through Entity: Utah State University & University of Cincinnati
MW2021-009 PROGRAM INCOME
Material Weakness
Criteria
Pursuant to 2 CFR 200 for award objectives and the regulations at 2 CFR 200.307, program
income is defined as “Gross income earned by the recipient that is directly generated by a
supported activity or earned as a result of the federal award during the period of performance” by
2 CFR Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements
for Federal Awards. Program income reporting is due forty five (45) days after the end of the
federal fiscal year. NSF requires that all cumulative program income is reported for all open
grants and agreements in the current year.
Condition
Program income consists of registration fees collected for training, meetings or workshops and
the proceeds from the sale of publications as a result of the federal award during the period of
performance. Program income is treated as an additive to the federal funds received by CUAHSI.
During a drawdown, program income reduces the amount that is requested to cover reimbursable
costs through the Flexible Billing module. This allows program income to be applied to the
award before a reimbursement is requested from NSF adding the value of program income
received to the awarded amount. Program income reporting is due forty five (45) days after the
end of the federal fiscal year. NSF requires that all cumulative program income is reported for all
open grants and agreements in the current year. CUAHSI program income totaled $31,525 for
the year ended December 31, 2021. CUAHSI failed to submit the required Program Income Reporting Worksheet by the required deadline of forty five (45) days after the end of the federal fiscal year (November 15, 2021) to ensure with the program income policies in accordance with the UG for the year ended December 31, 2021.
Cause & Context
Lack of resources and detailed attention to the risks, along with circumvention of controls has
resulted in weak internal controls, and conflicting or incomplete policies and procedures.
Effect
Non-compliance can lead to penalties, fines, or even termination of the contract. It may also
damage CUAHSI’s reputation and future eligibility for federal funding and jeopardize
CUAHSI’s ability to secure future grants or contracts from other funding agencies. Granting
organizations typically prioritize funding recipients with a track record of compliance and
accountability.
Questioned Costs
None
Prior Year Audit Finding
Yes, previously reported as MW2020-009.
Recommendation
The auditor recommends that CUAHSI develops and implements controls over policies
consistent with 2 CFR 200.307.
View of Responsible Official and Planned Corrective Action
See accompanying Corrective Action Plan.