Finding 2022-001 Criteria or Specific Requirement: Management is responsible for establishing policies and procedures for creating an appropriate financial management system to track federal grants in accordance with 2 CFR 200.508, including the preparation and presentation of the schedule of expenditures of federal awards. Condition: Grant revenue in the prior year was not accrued to present reimbursement grants in accordance with generally accepted accounting principles. Cause: Management records grant revenue at the time of the drawdown request without regard to the period the expenditures were incurred. Effect or Potential Effect: Grant revenue was presented in the incorrect period causing a misstatement in the schedule of expenditures of federal awards. Recommendation: We recommend the Organization implement a process to perform a financial close, including accruing expected grant revenue based on expenditures incurred during the reporting period. We also recommend the Organization implement a process to ensure the schedule of federal expenditures of federal awards is presented fairly. Views of responsible officials: Management agrees with the finding and will implement a process to review its financial closing procedures.
Finding 2022-002 Criteria or Specific Requirement: The Code of Federal Regulations Section 200 subpart E outlines the allowability of cost provisions, including indirect costs. Specifically, 2 CFR 200.403(d) states that costs should be accorded consistent treatment to be allowable, and 200.405 defines allocable costs. Condition: During our review of allowable expenses, it was noted that indirect costs were based on the grant budget and not supported by an indirect cost pool. Cause: The Organization has not implemented a cost allocation policy to track indirect costs. Effect or Potential Effect: Indirect expenses were charged to grants and allowability was unable to be determined. Questioned Costs: $40,242. Context: All cost charged as indirect cost to the research and development cluster were based on the grant budget and not supported by allocable costs. Repeat Finding: No Recommendation: We recommend the Organization implement methodology to track overhead expenses, pool them, and allocate to each grant using a reasonable basis for allocation. Views of responsible officials: Management agrees with the finding and will implement a process to pool its overhead costs and allocate them accordingly.
Finding 2022-003 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.322(b) states that the pass-through entity must evaluate the subrecipient's risk of noncompliance with Federal statutes and Section 200.332(d) states that the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subawards is used for authorized purposes. Condition: During our review of subrecipient monitoring, it was noted that no formal written policy is maintained. Cause: The Organization does not have written policies and procedures to monitor subrecipient's activities in accordance with the Uniform Guidance requirements. Effect or Potential Effect: The deficiency increases the risk that subawards could be spent for purposes other than those outlined in the grant agreements. Context: The Organization provides subawards to grant recipients. Its monitoring procedures consist of approvals over the expenditures but lack the requirements set forth by 2 CFR 200.332. Questioned costs: None noted. Repeat finding: No. Recommendation: We recommend the Organization's subrecipient monitoring policies and procedures be reviewed and updated for compliance with the Uniform Guidance requirements. Additionally, we recommend the Organization review all policies and procedures annually, or more frequently, if necessary, to reflect changes to laws, regulations, personnel, and/or internal procedures. Views of Responsible Officials: Management agrees with the finding and will implement a process to documents its policies and ensure they meet the subrecipient monitoring requirements.
Finding 2022-004 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.302(b)(6) requires the non-Federal entity to provide written procedures to implement the requirements of cash management as defined in 200.305. Condition: During our testing of cash management, approvals over the draw requests were omitted. Cause: Controls over approvals of the cash draw requests are not fully implemented. Effect or Potential Effect: The lack of approvals could lead to mishandling of the cash management. Context: Eight out of forty-six drawdown requests were sampled and four did not contain documented approvals. Questioned costs: None noted. Repeat Finding: no. Recommendation: We recommend the Organization implement policies, procedures, and training to ensure all grant draw requests are reviewed and approved prior to submission to the awarding agency. Views of Responsible Officials: Management agrees with the finding and will implement a process to document its policies and procedures.
Finding 2022-005 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.318 states that the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must confirm to the procurement standards identified in Sections 200.317 through 200.327. Condition: During our review of the procurement procedures, it was noted that no formal written policy is maintained. Cause: The Organization does not have a process for reviewing its written policies and procedures on a regular basis to ensure its activities conform to Uniform Guidance requirements. Effect or Potential Effect: The deficiency increases the risk that expenses could be disallowed if appropriate procurement procedures were not followed. Questioned costs: None note. Repeat Finding: No. Recommendation: We recommend the Organization document and implement its procurement policies and procedures for compliance with Uniform Guidance requirements. Additionally, we recommend the Organization review all policies and procedures annually, or more frequently, if necessary, to reflect changes to laws, regulations, personnel, and/or internal procedures. Views of Responsible Officials: Management agrees with the finding and will implement a process to document its policies and procedures.
Finding 2022-001 Criteria or Specific Requirement: Management is responsible for establishing policies and procedures for creating an appropriate financial management system to track federal grants in accordance with 2 CFR 200.508, including the preparation and presentation of the schedule of expenditures of federal awards. Condition: Grant revenue in the prior year was not accrued to present reimbursement grants in accordance with generally accepted accounting principles. Cause: Management records grant revenue at the time of the drawdown request without regard to the period the expenditures were incurred. Effect or Potential Effect: Grant revenue was presented in the incorrect period causing a misstatement in the schedule of expenditures of federal awards. Recommendation: We recommend the Organization implement a process to perform a financial close, including accruing expected grant revenue based on expenditures incurred during the reporting period. We also recommend the Organization implement a process to ensure the schedule of federal expenditures of federal awards is presented fairly. Views of responsible officials: Management agrees with the finding and will implement a process to review its financial closing procedures.
Finding 2022-002 Criteria or Specific Requirement: The Code of Federal Regulations Section 200 subpart E outlines the allowability of cost provisions, including indirect costs. Specifically, 2 CFR 200.403(d) states that costs should be accorded consistent treatment to be allowable, and 200.405 defines allocable costs. Condition: During our review of allowable expenses, it was noted that indirect costs were based on the grant budget and not supported by an indirect cost pool. Cause: The Organization has not implemented a cost allocation policy to track indirect costs. Effect or Potential Effect: Indirect expenses were charged to grants and allowability was unable to be determined. Questioned Costs: $40,242. Context: All cost charged as indirect cost to the research and development cluster were based on the grant budget and not supported by allocable costs. Repeat Finding: No Recommendation: We recommend the Organization implement methodology to track overhead expenses, pool them, and allocate to each grant using a reasonable basis for allocation. Views of responsible officials: Management agrees with the finding and will implement a process to pool its overhead costs and allocate them accordingly.
Finding 2022-003 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.322(b) states that the pass-through entity must evaluate the subrecipient's risk of noncompliance with Federal statutes and Section 200.332(d) states that the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subawards is used for authorized purposes. Condition: During our review of subrecipient monitoring, it was noted that no formal written policy is maintained. Cause: The Organization does not have written policies and procedures to monitor subrecipient's activities in accordance with the Uniform Guidance requirements. Effect or Potential Effect: The deficiency increases the risk that subawards could be spent for purposes other than those outlined in the grant agreements. Context: The Organization provides subawards to grant recipients. Its monitoring procedures consist of approvals over the expenditures but lack the requirements set forth by 2 CFR 200.332. Questioned costs: None noted. Repeat finding: No. Recommendation: We recommend the Organization's subrecipient monitoring policies and procedures be reviewed and updated for compliance with the Uniform Guidance requirements. Additionally, we recommend the Organization review all policies and procedures annually, or more frequently, if necessary, to reflect changes to laws, regulations, personnel, and/or internal procedures. Views of Responsible Officials: Management agrees with the finding and will implement a process to documents its policies and ensure they meet the subrecipient monitoring requirements.
Finding 2022-004 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.302(b)(6) requires the non-Federal entity to provide written procedures to implement the requirements of cash management as defined in 200.305. Condition: During our testing of cash management, approvals over the draw requests were omitted. Cause: Controls over approvals of the cash draw requests are not fully implemented. Effect or Potential Effect: The lack of approvals could lead to mishandling of the cash management. Context: Eight out of forty-six drawdown requests were sampled and four did not contain documented approvals. Questioned costs: None noted. Repeat Finding: no. Recommendation: We recommend the Organization implement policies, procedures, and training to ensure all grant draw requests are reviewed and approved prior to submission to the awarding agency. Views of Responsible Officials: Management agrees with the finding and will implement a process to document its policies and procedures.
Finding 2022-005 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.318 states that the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must confirm to the procurement standards identified in Sections 200.317 through 200.327. Condition: During our review of the procurement procedures, it was noted that no formal written policy is maintained. Cause: The Organization does not have a process for reviewing its written policies and procedures on a regular basis to ensure its activities conform to Uniform Guidance requirements. Effect or Potential Effect: The deficiency increases the risk that expenses could be disallowed if appropriate procurement procedures were not followed. Questioned costs: None note. Repeat Finding: No. Recommendation: We recommend the Organization document and implement its procurement policies and procedures for compliance with Uniform Guidance requirements. Additionally, we recommend the Organization review all policies and procedures annually, or more frequently, if necessary, to reflect changes to laws, regulations, personnel, and/or internal procedures. Views of Responsible Officials: Management agrees with the finding and will implement a process to document its policies and procedures.
Finding 2022-001 Criteria or Specific Requirement: Management is responsible for establishing policies and procedures for creating an appropriate financial management system to track federal grants in accordance with 2 CFR 200.508, including the preparation and presentation of the schedule of expenditures of federal awards. Condition: Grant revenue in the prior year was not accrued to present reimbursement grants in accordance with generally accepted accounting principles. Cause: Management records grant revenue at the time of the drawdown request without regard to the period the expenditures were incurred. Effect or Potential Effect: Grant revenue was presented in the incorrect period causing a misstatement in the schedule of expenditures of federal awards. Recommendation: We recommend the Organization implement a process to perform a financial close, including accruing expected grant revenue based on expenditures incurred during the reporting period. We also recommend the Organization implement a process to ensure the schedule of federal expenditures of federal awards is presented fairly. Views of responsible officials: Management agrees with the finding and will implement a process to review its financial closing procedures.
Finding 2022-002 Criteria or Specific Requirement: The Code of Federal Regulations Section 200 subpart E outlines the allowability of cost provisions, including indirect costs. Specifically, 2 CFR 200.403(d) states that costs should be accorded consistent treatment to be allowable, and 200.405 defines allocable costs. Condition: During our review of allowable expenses, it was noted that indirect costs were based on the grant budget and not supported by an indirect cost pool. Cause: The Organization has not implemented a cost allocation policy to track indirect costs. Effect or Potential Effect: Indirect expenses were charged to grants and allowability was unable to be determined. Questioned Costs: $40,242. Context: All cost charged as indirect cost to the research and development cluster were based on the grant budget and not supported by allocable costs. Repeat Finding: No Recommendation: We recommend the Organization implement methodology to track overhead expenses, pool them, and allocate to each grant using a reasonable basis for allocation. Views of responsible officials: Management agrees with the finding and will implement a process to pool its overhead costs and allocate them accordingly.
Finding 2022-003 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.322(b) states that the pass-through entity must evaluate the subrecipient's risk of noncompliance with Federal statutes and Section 200.332(d) states that the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subawards is used for authorized purposes. Condition: During our review of subrecipient monitoring, it was noted that no formal written policy is maintained. Cause: The Organization does not have written policies and procedures to monitor subrecipient's activities in accordance with the Uniform Guidance requirements. Effect or Potential Effect: The deficiency increases the risk that subawards could be spent for purposes other than those outlined in the grant agreements. Context: The Organization provides subawards to grant recipients. Its monitoring procedures consist of approvals over the expenditures but lack the requirements set forth by 2 CFR 200.332. Questioned costs: None noted. Repeat finding: No. Recommendation: We recommend the Organization's subrecipient monitoring policies and procedures be reviewed and updated for compliance with the Uniform Guidance requirements. Additionally, we recommend the Organization review all policies and procedures annually, or more frequently, if necessary, to reflect changes to laws, regulations, personnel, and/or internal procedures. Views of Responsible Officials: Management agrees with the finding and will implement a process to documents its policies and ensure they meet the subrecipient monitoring requirements.
Finding 2022-004 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.302(b)(6) requires the non-Federal entity to provide written procedures to implement the requirements of cash management as defined in 200.305. Condition: During our testing of cash management, approvals over the draw requests were omitted. Cause: Controls over approvals of the cash draw requests are not fully implemented. Effect or Potential Effect: The lack of approvals could lead to mishandling of the cash management. Context: Eight out of forty-six drawdown requests were sampled and four did not contain documented approvals. Questioned costs: None noted. Repeat Finding: no. Recommendation: We recommend the Organization implement policies, procedures, and training to ensure all grant draw requests are reviewed and approved prior to submission to the awarding agency. Views of Responsible Officials: Management agrees with the finding and will implement a process to document its policies and procedures.
Finding 2022-005 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.318 states that the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must confirm to the procurement standards identified in Sections 200.317 through 200.327. Condition: During our review of the procurement procedures, it was noted that no formal written policy is maintained. Cause: The Organization does not have a process for reviewing its written policies and procedures on a regular basis to ensure its activities conform to Uniform Guidance requirements. Effect or Potential Effect: The deficiency increases the risk that expenses could be disallowed if appropriate procurement procedures were not followed. Questioned costs: None note. Repeat Finding: No. Recommendation: We recommend the Organization document and implement its procurement policies and procedures for compliance with Uniform Guidance requirements. Additionally, we recommend the Organization review all policies and procedures annually, or more frequently, if necessary, to reflect changes to laws, regulations, personnel, and/or internal procedures. Views of Responsible Officials: Management agrees with the finding and will implement a process to document its policies and procedures.
Finding 2022-001 Criteria or Specific Requirement: Management is responsible for establishing policies and procedures for creating an appropriate financial management system to track federal grants in accordance with 2 CFR 200.508, including the preparation and presentation of the schedule of expenditures of federal awards. Condition: Grant revenue in the prior year was not accrued to present reimbursement grants in accordance with generally accepted accounting principles. Cause: Management records grant revenue at the time of the drawdown request without regard to the period the expenditures were incurred. Effect or Potential Effect: Grant revenue was presented in the incorrect period causing a misstatement in the schedule of expenditures of federal awards. Recommendation: We recommend the Organization implement a process to perform a financial close, including accruing expected grant revenue based on expenditures incurred during the reporting period. We also recommend the Organization implement a process to ensure the schedule of federal expenditures of federal awards is presented fairly. Views of responsible officials: Management agrees with the finding and will implement a process to review its financial closing procedures.
Finding 2022-002 Criteria or Specific Requirement: The Code of Federal Regulations Section 200 subpart E outlines the allowability of cost provisions, including indirect costs. Specifically, 2 CFR 200.403(d) states that costs should be accorded consistent treatment to be allowable, and 200.405 defines allocable costs. Condition: During our review of allowable expenses, it was noted that indirect costs were based on the grant budget and not supported by an indirect cost pool. Cause: The Organization has not implemented a cost allocation policy to track indirect costs. Effect or Potential Effect: Indirect expenses were charged to grants and allowability was unable to be determined. Questioned Costs: $40,242. Context: All cost charged as indirect cost to the research and development cluster were based on the grant budget and not supported by allocable costs. Repeat Finding: No Recommendation: We recommend the Organization implement methodology to track overhead expenses, pool them, and allocate to each grant using a reasonable basis for allocation. Views of responsible officials: Management agrees with the finding and will implement a process to pool its overhead costs and allocate them accordingly.
Finding 2022-003 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.322(b) states that the pass-through entity must evaluate the subrecipient's risk of noncompliance with Federal statutes and Section 200.332(d) states that the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subawards is used for authorized purposes. Condition: During our review of subrecipient monitoring, it was noted that no formal written policy is maintained. Cause: The Organization does not have written policies and procedures to monitor subrecipient's activities in accordance with the Uniform Guidance requirements. Effect or Potential Effect: The deficiency increases the risk that subawards could be spent for purposes other than those outlined in the grant agreements. Context: The Organization provides subawards to grant recipients. Its monitoring procedures consist of approvals over the expenditures but lack the requirements set forth by 2 CFR 200.332. Questioned costs: None noted. Repeat finding: No. Recommendation: We recommend the Organization's subrecipient monitoring policies and procedures be reviewed and updated for compliance with the Uniform Guidance requirements. Additionally, we recommend the Organization review all policies and procedures annually, or more frequently, if necessary, to reflect changes to laws, regulations, personnel, and/or internal procedures. Views of Responsible Officials: Management agrees with the finding and will implement a process to documents its policies and ensure they meet the subrecipient monitoring requirements.
Finding 2022-004 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.302(b)(6) requires the non-Federal entity to provide written procedures to implement the requirements of cash management as defined in 200.305. Condition: During our testing of cash management, approvals over the draw requests were omitted. Cause: Controls over approvals of the cash draw requests are not fully implemented. Effect or Potential Effect: The lack of approvals could lead to mishandling of the cash management. Context: Eight out of forty-six drawdown requests were sampled and four did not contain documented approvals. Questioned costs: None noted. Repeat Finding: no. Recommendation: We recommend the Organization implement policies, procedures, and training to ensure all grant draw requests are reviewed and approved prior to submission to the awarding agency. Views of Responsible Officials: Management agrees with the finding and will implement a process to document its policies and procedures.
Finding 2022-005 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.318 states that the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must confirm to the procurement standards identified in Sections 200.317 through 200.327. Condition: During our review of the procurement procedures, it was noted that no formal written policy is maintained. Cause: The Organization does not have a process for reviewing its written policies and procedures on a regular basis to ensure its activities conform to Uniform Guidance requirements. Effect or Potential Effect: The deficiency increases the risk that expenses could be disallowed if appropriate procurement procedures were not followed. Questioned costs: None note. Repeat Finding: No. Recommendation: We recommend the Organization document and implement its procurement policies and procedures for compliance with Uniform Guidance requirements. Additionally, we recommend the Organization review all policies and procedures annually, or more frequently, if necessary, to reflect changes to laws, regulations, personnel, and/or internal procedures. Views of Responsible Officials: Management agrees with the finding and will implement a process to document its policies and procedures.
Finding 2022-001 Criteria or Specific Requirement: Management is responsible for establishing policies and procedures for creating an appropriate financial management system to track federal grants in accordance with 2 CFR 200.508, including the preparation and presentation of the schedule of expenditures of federal awards. Condition: Grant revenue in the prior year was not accrued to present reimbursement grants in accordance with generally accepted accounting principles. Cause: Management records grant revenue at the time of the drawdown request without regard to the period the expenditures were incurred. Effect or Potential Effect: Grant revenue was presented in the incorrect period causing a misstatement in the schedule of expenditures of federal awards. Recommendation: We recommend the Organization implement a process to perform a financial close, including accruing expected grant revenue based on expenditures incurred during the reporting period. We also recommend the Organization implement a process to ensure the schedule of federal expenditures of federal awards is presented fairly. Views of responsible officials: Management agrees with the finding and will implement a process to review its financial closing procedures.
Finding 2022-002 Criteria or Specific Requirement: The Code of Federal Regulations Section 200 subpart E outlines the allowability of cost provisions, including indirect costs. Specifically, 2 CFR 200.403(d) states that costs should be accorded consistent treatment to be allowable, and 200.405 defines allocable costs. Condition: During our review of allowable expenses, it was noted that indirect costs were based on the grant budget and not supported by an indirect cost pool. Cause: The Organization has not implemented a cost allocation policy to track indirect costs. Effect or Potential Effect: Indirect expenses were charged to grants and allowability was unable to be determined. Questioned Costs: $40,242. Context: All cost charged as indirect cost to the research and development cluster were based on the grant budget and not supported by allocable costs. Repeat Finding: No Recommendation: We recommend the Organization implement methodology to track overhead expenses, pool them, and allocate to each grant using a reasonable basis for allocation. Views of responsible officials: Management agrees with the finding and will implement a process to pool its overhead costs and allocate them accordingly.
Finding 2022-003 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.322(b) states that the pass-through entity must evaluate the subrecipient's risk of noncompliance with Federal statutes and Section 200.332(d) states that the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subawards is used for authorized purposes. Condition: During our review of subrecipient monitoring, it was noted that no formal written policy is maintained. Cause: The Organization does not have written policies and procedures to monitor subrecipient's activities in accordance with the Uniform Guidance requirements. Effect or Potential Effect: The deficiency increases the risk that subawards could be spent for purposes other than those outlined in the grant agreements. Context: The Organization provides subawards to grant recipients. Its monitoring procedures consist of approvals over the expenditures but lack the requirements set forth by 2 CFR 200.332. Questioned costs: None noted. Repeat finding: No. Recommendation: We recommend the Organization's subrecipient monitoring policies and procedures be reviewed and updated for compliance with the Uniform Guidance requirements. Additionally, we recommend the Organization review all policies and procedures annually, or more frequently, if necessary, to reflect changes to laws, regulations, personnel, and/or internal procedures. Views of Responsible Officials: Management agrees with the finding and will implement a process to documents its policies and ensure they meet the subrecipient monitoring requirements.
Finding 2022-004 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.302(b)(6) requires the non-Federal entity to provide written procedures to implement the requirements of cash management as defined in 200.305. Condition: During our testing of cash management, approvals over the draw requests were omitted. Cause: Controls over approvals of the cash draw requests are not fully implemented. Effect or Potential Effect: The lack of approvals could lead to mishandling of the cash management. Context: Eight out of forty-six drawdown requests were sampled and four did not contain documented approvals. Questioned costs: None noted. Repeat Finding: no. Recommendation: We recommend the Organization implement policies, procedures, and training to ensure all grant draw requests are reviewed and approved prior to submission to the awarding agency. Views of Responsible Officials: Management agrees with the finding and will implement a process to document its policies and procedures.
Finding 2022-005 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.318 states that the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must confirm to the procurement standards identified in Sections 200.317 through 200.327. Condition: During our review of the procurement procedures, it was noted that no formal written policy is maintained. Cause: The Organization does not have a process for reviewing its written policies and procedures on a regular basis to ensure its activities conform to Uniform Guidance requirements. Effect or Potential Effect: The deficiency increases the risk that expenses could be disallowed if appropriate procurement procedures were not followed. Questioned costs: None note. Repeat Finding: No. Recommendation: We recommend the Organization document and implement its procurement policies and procedures for compliance with Uniform Guidance requirements. Additionally, we recommend the Organization review all policies and procedures annually, or more frequently, if necessary, to reflect changes to laws, regulations, personnel, and/or internal procedures. Views of Responsible Officials: Management agrees with the finding and will implement a process to document its policies and procedures.
Finding 2022-001 Criteria or Specific Requirement: Management is responsible for establishing policies and procedures for creating an appropriate financial management system to track federal grants in accordance with 2 CFR 200.508, including the preparation and presentation of the schedule of expenditures of federal awards. Condition: Grant revenue in the prior year was not accrued to present reimbursement grants in accordance with generally accepted accounting principles. Cause: Management records grant revenue at the time of the drawdown request without regard to the period the expenditures were incurred. Effect or Potential Effect: Grant revenue was presented in the incorrect period causing a misstatement in the schedule of expenditures of federal awards. Recommendation: We recommend the Organization implement a process to perform a financial close, including accruing expected grant revenue based on expenditures incurred during the reporting period. We also recommend the Organization implement a process to ensure the schedule of federal expenditures of federal awards is presented fairly. Views of responsible officials: Management agrees with the finding and will implement a process to review its financial closing procedures.
Finding 2022-002 Criteria or Specific Requirement: The Code of Federal Regulations Section 200 subpart E outlines the allowability of cost provisions, including indirect costs. Specifically, 2 CFR 200.403(d) states that costs should be accorded consistent treatment to be allowable, and 200.405 defines allocable costs. Condition: During our review of allowable expenses, it was noted that indirect costs were based on the grant budget and not supported by an indirect cost pool. Cause: The Organization has not implemented a cost allocation policy to track indirect costs. Effect or Potential Effect: Indirect expenses were charged to grants and allowability was unable to be determined. Questioned Costs: $40,242. Context: All cost charged as indirect cost to the research and development cluster were based on the grant budget and not supported by allocable costs. Repeat Finding: No Recommendation: We recommend the Organization implement methodology to track overhead expenses, pool them, and allocate to each grant using a reasonable basis for allocation. Views of responsible officials: Management agrees with the finding and will implement a process to pool its overhead costs and allocate them accordingly.
Finding 2022-003 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.322(b) states that the pass-through entity must evaluate the subrecipient's risk of noncompliance with Federal statutes and Section 200.332(d) states that the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subawards is used for authorized purposes. Condition: During our review of subrecipient monitoring, it was noted that no formal written policy is maintained. Cause: The Organization does not have written policies and procedures to monitor subrecipient's activities in accordance with the Uniform Guidance requirements. Effect or Potential Effect: The deficiency increases the risk that subawards could be spent for purposes other than those outlined in the grant agreements. Context: The Organization provides subawards to grant recipients. Its monitoring procedures consist of approvals over the expenditures but lack the requirements set forth by 2 CFR 200.332. Questioned costs: None noted. Repeat finding: No. Recommendation: We recommend the Organization's subrecipient monitoring policies and procedures be reviewed and updated for compliance with the Uniform Guidance requirements. Additionally, we recommend the Organization review all policies and procedures annually, or more frequently, if necessary, to reflect changes to laws, regulations, personnel, and/or internal procedures. Views of Responsible Officials: Management agrees with the finding and will implement a process to documents its policies and ensure they meet the subrecipient monitoring requirements.
Finding 2022-004 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.302(b)(6) requires the non-Federal entity to provide written procedures to implement the requirements of cash management as defined in 200.305. Condition: During our testing of cash management, approvals over the draw requests were omitted. Cause: Controls over approvals of the cash draw requests are not fully implemented. Effect or Potential Effect: The lack of approvals could lead to mishandling of the cash management. Context: Eight out of forty-six drawdown requests were sampled and four did not contain documented approvals. Questioned costs: None noted. Repeat Finding: no. Recommendation: We recommend the Organization implement policies, procedures, and training to ensure all grant draw requests are reviewed and approved prior to submission to the awarding agency. Views of Responsible Officials: Management agrees with the finding and will implement a process to document its policies and procedures.
Finding 2022-005 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.318 states that the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must confirm to the procurement standards identified in Sections 200.317 through 200.327. Condition: During our review of the procurement procedures, it was noted that no formal written policy is maintained. Cause: The Organization does not have a process for reviewing its written policies and procedures on a regular basis to ensure its activities conform to Uniform Guidance requirements. Effect or Potential Effect: The deficiency increases the risk that expenses could be disallowed if appropriate procurement procedures were not followed. Questioned costs: None note. Repeat Finding: No. Recommendation: We recommend the Organization document and implement its procurement policies and procedures for compliance with Uniform Guidance requirements. Additionally, we recommend the Organization review all policies and procedures annually, or more frequently, if necessary, to reflect changes to laws, regulations, personnel, and/or internal procedures. Views of Responsible Officials: Management agrees with the finding and will implement a process to document its policies and procedures.
Finding 2022-001 Criteria or Specific Requirement: Management is responsible for establishing policies and procedures for creating an appropriate financial management system to track federal grants in accordance with 2 CFR 200.508, including the preparation and presentation of the schedule of expenditures of federal awards. Condition: Grant revenue in the prior year was not accrued to present reimbursement grants in accordance with generally accepted accounting principles. Cause: Management records grant revenue at the time of the drawdown request without regard to the period the expenditures were incurred. Effect or Potential Effect: Grant revenue was presented in the incorrect period causing a misstatement in the schedule of expenditures of federal awards. Recommendation: We recommend the Organization implement a process to perform a financial close, including accruing expected grant revenue based on expenditures incurred during the reporting period. We also recommend the Organization implement a process to ensure the schedule of federal expenditures of federal awards is presented fairly. Views of responsible officials: Management agrees with the finding and will implement a process to review its financial closing procedures.
Finding 2022-002 Criteria or Specific Requirement: The Code of Federal Regulations Section 200 subpart E outlines the allowability of cost provisions, including indirect costs. Specifically, 2 CFR 200.403(d) states that costs should be accorded consistent treatment to be allowable, and 200.405 defines allocable costs. Condition: During our review of allowable expenses, it was noted that indirect costs were based on the grant budget and not supported by an indirect cost pool. Cause: The Organization has not implemented a cost allocation policy to track indirect costs. Effect or Potential Effect: Indirect expenses were charged to grants and allowability was unable to be determined. Questioned Costs: $40,242. Context: All cost charged as indirect cost to the research and development cluster were based on the grant budget and not supported by allocable costs. Repeat Finding: No Recommendation: We recommend the Organization implement methodology to track overhead expenses, pool them, and allocate to each grant using a reasonable basis for allocation. Views of responsible officials: Management agrees with the finding and will implement a process to pool its overhead costs and allocate them accordingly.
Finding 2022-003 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.322(b) states that the pass-through entity must evaluate the subrecipient's risk of noncompliance with Federal statutes and Section 200.332(d) states that the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subawards is used for authorized purposes. Condition: During our review of subrecipient monitoring, it was noted that no formal written policy is maintained. Cause: The Organization does not have written policies and procedures to monitor subrecipient's activities in accordance with the Uniform Guidance requirements. Effect or Potential Effect: The deficiency increases the risk that subawards could be spent for purposes other than those outlined in the grant agreements. Context: The Organization provides subawards to grant recipients. Its monitoring procedures consist of approvals over the expenditures but lack the requirements set forth by 2 CFR 200.332. Questioned costs: None noted. Repeat finding: No. Recommendation: We recommend the Organization's subrecipient monitoring policies and procedures be reviewed and updated for compliance with the Uniform Guidance requirements. Additionally, we recommend the Organization review all policies and procedures annually, or more frequently, if necessary, to reflect changes to laws, regulations, personnel, and/or internal procedures. Views of Responsible Officials: Management agrees with the finding and will implement a process to documents its policies and ensure they meet the subrecipient monitoring requirements.
Finding 2022-004 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.302(b)(6) requires the non-Federal entity to provide written procedures to implement the requirements of cash management as defined in 200.305. Condition: During our testing of cash management, approvals over the draw requests were omitted. Cause: Controls over approvals of the cash draw requests are not fully implemented. Effect or Potential Effect: The lack of approvals could lead to mishandling of the cash management. Context: Eight out of forty-six drawdown requests were sampled and four did not contain documented approvals. Questioned costs: None noted. Repeat Finding: no. Recommendation: We recommend the Organization implement policies, procedures, and training to ensure all grant draw requests are reviewed and approved prior to submission to the awarding agency. Views of Responsible Officials: Management agrees with the finding and will implement a process to document its policies and procedures.
Finding 2022-005 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.318 states that the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must confirm to the procurement standards identified in Sections 200.317 through 200.327. Condition: During our review of the procurement procedures, it was noted that no formal written policy is maintained. Cause: The Organization does not have a process for reviewing its written policies and procedures on a regular basis to ensure its activities conform to Uniform Guidance requirements. Effect or Potential Effect: The deficiency increases the risk that expenses could be disallowed if appropriate procurement procedures were not followed. Questioned costs: None note. Repeat Finding: No. Recommendation: We recommend the Organization document and implement its procurement policies and procedures for compliance with Uniform Guidance requirements. Additionally, we recommend the Organization review all policies and procedures annually, or more frequently, if necessary, to reflect changes to laws, regulations, personnel, and/or internal procedures. Views of Responsible Officials: Management agrees with the finding and will implement a process to document its policies and procedures.
Finding 2022-001 Criteria or Specific Requirement: Management is responsible for establishing policies and procedures for creating an appropriate financial management system to track federal grants in accordance with 2 CFR 200.508, including the preparation and presentation of the schedule of expenditures of federal awards. Condition: Grant revenue in the prior year was not accrued to present reimbursement grants in accordance with generally accepted accounting principles. Cause: Management records grant revenue at the time of the drawdown request without regard to the period the expenditures were incurred. Effect or Potential Effect: Grant revenue was presented in the incorrect period causing a misstatement in the schedule of expenditures of federal awards. Recommendation: We recommend the Organization implement a process to perform a financial close, including accruing expected grant revenue based on expenditures incurred during the reporting period. We also recommend the Organization implement a process to ensure the schedule of federal expenditures of federal awards is presented fairly. Views of responsible officials: Management agrees with the finding and will implement a process to review its financial closing procedures.
Finding 2022-002 Criteria or Specific Requirement: The Code of Federal Regulations Section 200 subpart E outlines the allowability of cost provisions, including indirect costs. Specifically, 2 CFR 200.403(d) states that costs should be accorded consistent treatment to be allowable, and 200.405 defines allocable costs. Condition: During our review of allowable expenses, it was noted that indirect costs were based on the grant budget and not supported by an indirect cost pool. Cause: The Organization has not implemented a cost allocation policy to track indirect costs. Effect or Potential Effect: Indirect expenses were charged to grants and allowability was unable to be determined. Questioned Costs: $40,242. Context: All cost charged as indirect cost to the research and development cluster were based on the grant budget and not supported by allocable costs. Repeat Finding: No Recommendation: We recommend the Organization implement methodology to track overhead expenses, pool them, and allocate to each grant using a reasonable basis for allocation. Views of responsible officials: Management agrees with the finding and will implement a process to pool its overhead costs and allocate them accordingly.
Finding 2022-003 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.322(b) states that the pass-through entity must evaluate the subrecipient's risk of noncompliance with Federal statutes and Section 200.332(d) states that the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subawards is used for authorized purposes. Condition: During our review of subrecipient monitoring, it was noted that no formal written policy is maintained. Cause: The Organization does not have written policies and procedures to monitor subrecipient's activities in accordance with the Uniform Guidance requirements. Effect or Potential Effect: The deficiency increases the risk that subawards could be spent for purposes other than those outlined in the grant agreements. Context: The Organization provides subawards to grant recipients. Its monitoring procedures consist of approvals over the expenditures but lack the requirements set forth by 2 CFR 200.332. Questioned costs: None noted. Repeat finding: No. Recommendation: We recommend the Organization's subrecipient monitoring policies and procedures be reviewed and updated for compliance with the Uniform Guidance requirements. Additionally, we recommend the Organization review all policies and procedures annually, or more frequently, if necessary, to reflect changes to laws, regulations, personnel, and/or internal procedures. Views of Responsible Officials: Management agrees with the finding and will implement a process to documents its policies and ensure they meet the subrecipient monitoring requirements.
Finding 2022-004 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.302(b)(6) requires the non-Federal entity to provide written procedures to implement the requirements of cash management as defined in 200.305. Condition: During our testing of cash management, approvals over the draw requests were omitted. Cause: Controls over approvals of the cash draw requests are not fully implemented. Effect or Potential Effect: The lack of approvals could lead to mishandling of the cash management. Context: Eight out of forty-six drawdown requests were sampled and four did not contain documented approvals. Questioned costs: None noted. Repeat Finding: no. Recommendation: We recommend the Organization implement policies, procedures, and training to ensure all grant draw requests are reviewed and approved prior to submission to the awarding agency. Views of Responsible Officials: Management agrees with the finding and will implement a process to document its policies and procedures.
Finding 2022-005 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.318 states that the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must confirm to the procurement standards identified in Sections 200.317 through 200.327. Condition: During our review of the procurement procedures, it was noted that no formal written policy is maintained. Cause: The Organization does not have a process for reviewing its written policies and procedures on a regular basis to ensure its activities conform to Uniform Guidance requirements. Effect or Potential Effect: The deficiency increases the risk that expenses could be disallowed if appropriate procurement procedures were not followed. Questioned costs: None note. Repeat Finding: No. Recommendation: We recommend the Organization document and implement its procurement policies and procedures for compliance with Uniform Guidance requirements. Additionally, we recommend the Organization review all policies and procedures annually, or more frequently, if necessary, to reflect changes to laws, regulations, personnel, and/or internal procedures. Views of Responsible Officials: Management agrees with the finding and will implement a process to document its policies and procedures.
Finding 2022-001 Criteria or Specific Requirement: Management is responsible for establishing policies and procedures for creating an appropriate financial management system to track federal grants in accordance with 2 CFR 200.508, including the preparation and presentation of the schedule of expenditures of federal awards. Condition: Grant revenue in the prior year was not accrued to present reimbursement grants in accordance with generally accepted accounting principles. Cause: Management records grant revenue at the time of the drawdown request without regard to the period the expenditures were incurred. Effect or Potential Effect: Grant revenue was presented in the incorrect period causing a misstatement in the schedule of expenditures of federal awards. Recommendation: We recommend the Organization implement a process to perform a financial close, including accruing expected grant revenue based on expenditures incurred during the reporting period. We also recommend the Organization implement a process to ensure the schedule of federal expenditures of federal awards is presented fairly. Views of responsible officials: Management agrees with the finding and will implement a process to review its financial closing procedures.
Finding 2022-002 Criteria or Specific Requirement: The Code of Federal Regulations Section 200 subpart E outlines the allowability of cost provisions, including indirect costs. Specifically, 2 CFR 200.403(d) states that costs should be accorded consistent treatment to be allowable, and 200.405 defines allocable costs. Condition: During our review of allowable expenses, it was noted that indirect costs were based on the grant budget and not supported by an indirect cost pool. Cause: The Organization has not implemented a cost allocation policy to track indirect costs. Effect or Potential Effect: Indirect expenses were charged to grants and allowability was unable to be determined. Questioned Costs: $40,242. Context: All cost charged as indirect cost to the research and development cluster were based on the grant budget and not supported by allocable costs. Repeat Finding: No Recommendation: We recommend the Organization implement methodology to track overhead expenses, pool them, and allocate to each grant using a reasonable basis for allocation. Views of responsible officials: Management agrees with the finding and will implement a process to pool its overhead costs and allocate them accordingly.
Finding 2022-003 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.322(b) states that the pass-through entity must evaluate the subrecipient's risk of noncompliance with Federal statutes and Section 200.332(d) states that the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subawards is used for authorized purposes. Condition: During our review of subrecipient monitoring, it was noted that no formal written policy is maintained. Cause: The Organization does not have written policies and procedures to monitor subrecipient's activities in accordance with the Uniform Guidance requirements. Effect or Potential Effect: The deficiency increases the risk that subawards could be spent for purposes other than those outlined in the grant agreements. Context: The Organization provides subawards to grant recipients. Its monitoring procedures consist of approvals over the expenditures but lack the requirements set forth by 2 CFR 200.332. Questioned costs: None noted. Repeat finding: No. Recommendation: We recommend the Organization's subrecipient monitoring policies and procedures be reviewed and updated for compliance with the Uniform Guidance requirements. Additionally, we recommend the Organization review all policies and procedures annually, or more frequently, if necessary, to reflect changes to laws, regulations, personnel, and/or internal procedures. Views of Responsible Officials: Management agrees with the finding and will implement a process to documents its policies and ensure they meet the subrecipient monitoring requirements.
Finding 2022-004 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.302(b)(6) requires the non-Federal entity to provide written procedures to implement the requirements of cash management as defined in 200.305. Condition: During our testing of cash management, approvals over the draw requests were omitted. Cause: Controls over approvals of the cash draw requests are not fully implemented. Effect or Potential Effect: The lack of approvals could lead to mishandling of the cash management. Context: Eight out of forty-six drawdown requests were sampled and four did not contain documented approvals. Questioned costs: None noted. Repeat Finding: no. Recommendation: We recommend the Organization implement policies, procedures, and training to ensure all grant draw requests are reviewed and approved prior to submission to the awarding agency. Views of Responsible Officials: Management agrees with the finding and will implement a process to document its policies and procedures.
Finding 2022-005 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.318 states that the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must confirm to the procurement standards identified in Sections 200.317 through 200.327. Condition: During our review of the procurement procedures, it was noted that no formal written policy is maintained. Cause: The Organization does not have a process for reviewing its written policies and procedures on a regular basis to ensure its activities conform to Uniform Guidance requirements. Effect or Potential Effect: The deficiency increases the risk that expenses could be disallowed if appropriate procurement procedures were not followed. Questioned costs: None note. Repeat Finding: No. Recommendation: We recommend the Organization document and implement its procurement policies and procedures for compliance with Uniform Guidance requirements. Additionally, we recommend the Organization review all policies and procedures annually, or more frequently, if necessary, to reflect changes to laws, regulations, personnel, and/or internal procedures. Views of Responsible Officials: Management agrees with the finding and will implement a process to document its policies and procedures.
Finding 2022-001 Criteria or Specific Requirement: Management is responsible for establishing policies and procedures for creating an appropriate financial management system to track federal grants in accordance with 2 CFR 200.508, including the preparation and presentation of the schedule of expenditures of federal awards. Condition: Grant revenue in the prior year was not accrued to present reimbursement grants in accordance with generally accepted accounting principles. Cause: Management records grant revenue at the time of the drawdown request without regard to the period the expenditures were incurred. Effect or Potential Effect: Grant revenue was presented in the incorrect period causing a misstatement in the schedule of expenditures of federal awards. Recommendation: We recommend the Organization implement a process to perform a financial close, including accruing expected grant revenue based on expenditures incurred during the reporting period. We also recommend the Organization implement a process to ensure the schedule of federal expenditures of federal awards is presented fairly. Views of responsible officials: Management agrees with the finding and will implement a process to review its financial closing procedures.
Finding 2022-002 Criteria or Specific Requirement: The Code of Federal Regulations Section 200 subpart E outlines the allowability of cost provisions, including indirect costs. Specifically, 2 CFR 200.403(d) states that costs should be accorded consistent treatment to be allowable, and 200.405 defines allocable costs. Condition: During our review of allowable expenses, it was noted that indirect costs were based on the grant budget and not supported by an indirect cost pool. Cause: The Organization has not implemented a cost allocation policy to track indirect costs. Effect or Potential Effect: Indirect expenses were charged to grants and allowability was unable to be determined. Questioned Costs: $40,242. Context: All cost charged as indirect cost to the research and development cluster were based on the grant budget and not supported by allocable costs. Repeat Finding: No Recommendation: We recommend the Organization implement methodology to track overhead expenses, pool them, and allocate to each grant using a reasonable basis for allocation. Views of responsible officials: Management agrees with the finding and will implement a process to pool its overhead costs and allocate them accordingly.
Finding 2022-003 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.322(b) states that the pass-through entity must evaluate the subrecipient's risk of noncompliance with Federal statutes and Section 200.332(d) states that the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subawards is used for authorized purposes. Condition: During our review of subrecipient monitoring, it was noted that no formal written policy is maintained. Cause: The Organization does not have written policies and procedures to monitor subrecipient's activities in accordance with the Uniform Guidance requirements. Effect or Potential Effect: The deficiency increases the risk that subawards could be spent for purposes other than those outlined in the grant agreements. Context: The Organization provides subawards to grant recipients. Its monitoring procedures consist of approvals over the expenditures but lack the requirements set forth by 2 CFR 200.332. Questioned costs: None noted. Repeat finding: No. Recommendation: We recommend the Organization's subrecipient monitoring policies and procedures be reviewed and updated for compliance with the Uniform Guidance requirements. Additionally, we recommend the Organization review all policies and procedures annually, or more frequently, if necessary, to reflect changes to laws, regulations, personnel, and/or internal procedures. Views of Responsible Officials: Management agrees with the finding and will implement a process to documents its policies and ensure they meet the subrecipient monitoring requirements.
Finding 2022-004 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.302(b)(6) requires the non-Federal entity to provide written procedures to implement the requirements of cash management as defined in 200.305. Condition: During our testing of cash management, approvals over the draw requests were omitted. Cause: Controls over approvals of the cash draw requests are not fully implemented. Effect or Potential Effect: The lack of approvals could lead to mishandling of the cash management. Context: Eight out of forty-six drawdown requests were sampled and four did not contain documented approvals. Questioned costs: None noted. Repeat Finding: no. Recommendation: We recommend the Organization implement policies, procedures, and training to ensure all grant draw requests are reviewed and approved prior to submission to the awarding agency. Views of Responsible Officials: Management agrees with the finding and will implement a process to document its policies and procedures.
Finding 2022-005 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.318 states that the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must confirm to the procurement standards identified in Sections 200.317 through 200.327. Condition: During our review of the procurement procedures, it was noted that no formal written policy is maintained. Cause: The Organization does not have a process for reviewing its written policies and procedures on a regular basis to ensure its activities conform to Uniform Guidance requirements. Effect or Potential Effect: The deficiency increases the risk that expenses could be disallowed if appropriate procurement procedures were not followed. Questioned costs: None note. Repeat Finding: No. Recommendation: We recommend the Organization document and implement its procurement policies and procedures for compliance with Uniform Guidance requirements. Additionally, we recommend the Organization review all policies and procedures annually, or more frequently, if necessary, to reflect changes to laws, regulations, personnel, and/or internal procedures. Views of Responsible Officials: Management agrees with the finding and will implement a process to document its policies and procedures.
Finding 2022-001 Criteria or Specific Requirement: Management is responsible for establishing policies and procedures for creating an appropriate financial management system to track federal grants in accordance with 2 CFR 200.508, including the preparation and presentation of the schedule of expenditures of federal awards. Condition: Grant revenue in the prior year was not accrued to present reimbursement grants in accordance with generally accepted accounting principles. Cause: Management records grant revenue at the time of the drawdown request without regard to the period the expenditures were incurred. Effect or Potential Effect: Grant revenue was presented in the incorrect period causing a misstatement in the schedule of expenditures of federal awards. Recommendation: We recommend the Organization implement a process to perform a financial close, including accruing expected grant revenue based on expenditures incurred during the reporting period. We also recommend the Organization implement a process to ensure the schedule of federal expenditures of federal awards is presented fairly. Views of responsible officials: Management agrees with the finding and will implement a process to review its financial closing procedures.
Finding 2022-002 Criteria or Specific Requirement: The Code of Federal Regulations Section 200 subpart E outlines the allowability of cost provisions, including indirect costs. Specifically, 2 CFR 200.403(d) states that costs should be accorded consistent treatment to be allowable, and 200.405 defines allocable costs. Condition: During our review of allowable expenses, it was noted that indirect costs were based on the grant budget and not supported by an indirect cost pool. Cause: The Organization has not implemented a cost allocation policy to track indirect costs. Effect or Potential Effect: Indirect expenses were charged to grants and allowability was unable to be determined. Questioned Costs: $40,242. Context: All cost charged as indirect cost to the research and development cluster were based on the grant budget and not supported by allocable costs. Repeat Finding: No Recommendation: We recommend the Organization implement methodology to track overhead expenses, pool them, and allocate to each grant using a reasonable basis for allocation. Views of responsible officials: Management agrees with the finding and will implement a process to pool its overhead costs and allocate them accordingly.
Finding 2022-003 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.322(b) states that the pass-through entity must evaluate the subrecipient's risk of noncompliance with Federal statutes and Section 200.332(d) states that the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subawards is used for authorized purposes. Condition: During our review of subrecipient monitoring, it was noted that no formal written policy is maintained. Cause: The Organization does not have written policies and procedures to monitor subrecipient's activities in accordance with the Uniform Guidance requirements. Effect or Potential Effect: The deficiency increases the risk that subawards could be spent for purposes other than those outlined in the grant agreements. Context: The Organization provides subawards to grant recipients. Its monitoring procedures consist of approvals over the expenditures but lack the requirements set forth by 2 CFR 200.332. Questioned costs: None noted. Repeat finding: No. Recommendation: We recommend the Organization's subrecipient monitoring policies and procedures be reviewed and updated for compliance with the Uniform Guidance requirements. Additionally, we recommend the Organization review all policies and procedures annually, or more frequently, if necessary, to reflect changes to laws, regulations, personnel, and/or internal procedures. Views of Responsible Officials: Management agrees with the finding and will implement a process to documents its policies and ensure they meet the subrecipient monitoring requirements.
Finding 2022-004 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.302(b)(6) requires the non-Federal entity to provide written procedures to implement the requirements of cash management as defined in 200.305. Condition: During our testing of cash management, approvals over the draw requests were omitted. Cause: Controls over approvals of the cash draw requests are not fully implemented. Effect or Potential Effect: The lack of approvals could lead to mishandling of the cash management. Context: Eight out of forty-six drawdown requests were sampled and four did not contain documented approvals. Questioned costs: None noted. Repeat Finding: no. Recommendation: We recommend the Organization implement policies, procedures, and training to ensure all grant draw requests are reviewed and approved prior to submission to the awarding agency. Views of Responsible Officials: Management agrees with the finding and will implement a process to document its policies and procedures.
Finding 2022-005 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.318 states that the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must confirm to the procurement standards identified in Sections 200.317 through 200.327. Condition: During our review of the procurement procedures, it was noted that no formal written policy is maintained. Cause: The Organization does not have a process for reviewing its written policies and procedures on a regular basis to ensure its activities conform to Uniform Guidance requirements. Effect or Potential Effect: The deficiency increases the risk that expenses could be disallowed if appropriate procurement procedures were not followed. Questioned costs: None note. Repeat Finding: No. Recommendation: We recommend the Organization document and implement its procurement policies and procedures for compliance with Uniform Guidance requirements. Additionally, we recommend the Organization review all policies and procedures annually, or more frequently, if necessary, to reflect changes to laws, regulations, personnel, and/or internal procedures. Views of Responsible Officials: Management agrees with the finding and will implement a process to document its policies and procedures.
Finding 2022-001 Criteria or Specific Requirement: Management is responsible for establishing policies and procedures for creating an appropriate financial management system to track federal grants in accordance with 2 CFR 200.508, including the preparation and presentation of the schedule of expenditures of federal awards. Condition: Grant revenue in the prior year was not accrued to present reimbursement grants in accordance with generally accepted accounting principles. Cause: Management records grant revenue at the time of the drawdown request without regard to the period the expenditures were incurred. Effect or Potential Effect: Grant revenue was presented in the incorrect period causing a misstatement in the schedule of expenditures of federal awards. Recommendation: We recommend the Organization implement a process to perform a financial close, including accruing expected grant revenue based on expenditures incurred during the reporting period. We also recommend the Organization implement a process to ensure the schedule of federal expenditures of federal awards is presented fairly. Views of responsible officials: Management agrees with the finding and will implement a process to review its financial closing procedures.
Finding 2022-002 Criteria or Specific Requirement: The Code of Federal Regulations Section 200 subpart E outlines the allowability of cost provisions, including indirect costs. Specifically, 2 CFR 200.403(d) states that costs should be accorded consistent treatment to be allowable, and 200.405 defines allocable costs. Condition: During our review of allowable expenses, it was noted that indirect costs were based on the grant budget and not supported by an indirect cost pool. Cause: The Organization has not implemented a cost allocation policy to track indirect costs. Effect or Potential Effect: Indirect expenses were charged to grants and allowability was unable to be determined. Questioned Costs: $40,242. Context: All cost charged as indirect cost to the research and development cluster were based on the grant budget and not supported by allocable costs. Repeat Finding: No Recommendation: We recommend the Organization implement methodology to track overhead expenses, pool them, and allocate to each grant using a reasonable basis for allocation. Views of responsible officials: Management agrees with the finding and will implement a process to pool its overhead costs and allocate them accordingly.
Finding 2022-003 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.322(b) states that the pass-through entity must evaluate the subrecipient's risk of noncompliance with Federal statutes and Section 200.332(d) states that the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subawards is used for authorized purposes. Condition: During our review of subrecipient monitoring, it was noted that no formal written policy is maintained. Cause: The Organization does not have written policies and procedures to monitor subrecipient's activities in accordance with the Uniform Guidance requirements. Effect or Potential Effect: The deficiency increases the risk that subawards could be spent for purposes other than those outlined in the grant agreements. Context: The Organization provides subawards to grant recipients. Its monitoring procedures consist of approvals over the expenditures but lack the requirements set forth by 2 CFR 200.332. Questioned costs: None noted. Repeat finding: No. Recommendation: We recommend the Organization's subrecipient monitoring policies and procedures be reviewed and updated for compliance with the Uniform Guidance requirements. Additionally, we recommend the Organization review all policies and procedures annually, or more frequently, if necessary, to reflect changes to laws, regulations, personnel, and/or internal procedures. Views of Responsible Officials: Management agrees with the finding and will implement a process to documents its policies and ensure they meet the subrecipient monitoring requirements.
Finding 2022-004 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.302(b)(6) requires the non-Federal entity to provide written procedures to implement the requirements of cash management as defined in 200.305. Condition: During our testing of cash management, approvals over the draw requests were omitted. Cause: Controls over approvals of the cash draw requests are not fully implemented. Effect or Potential Effect: The lack of approvals could lead to mishandling of the cash management. Context: Eight out of forty-six drawdown requests were sampled and four did not contain documented approvals. Questioned costs: None noted. Repeat Finding: no. Recommendation: We recommend the Organization implement policies, procedures, and training to ensure all grant draw requests are reviewed and approved prior to submission to the awarding agency. Views of Responsible Officials: Management agrees with the finding and will implement a process to document its policies and procedures.
Finding 2022-005 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.318 states that the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must confirm to the procurement standards identified in Sections 200.317 through 200.327. Condition: During our review of the procurement procedures, it was noted that no formal written policy is maintained. Cause: The Organization does not have a process for reviewing its written policies and procedures on a regular basis to ensure its activities conform to Uniform Guidance requirements. Effect or Potential Effect: The deficiency increases the risk that expenses could be disallowed if appropriate procurement procedures were not followed. Questioned costs: None note. Repeat Finding: No. Recommendation: We recommend the Organization document and implement its procurement policies and procedures for compliance with Uniform Guidance requirements. Additionally, we recommend the Organization review all policies and procedures annually, or more frequently, if necessary, to reflect changes to laws, regulations, personnel, and/or internal procedures. Views of Responsible Officials: Management agrees with the finding and will implement a process to document its policies and procedures.