FAC Explorer

Audit 361981

FY End
2024-12-31
Total Expended
$1.32M
Findings
176
Programs
16
Organization: Federation of American Societies for Experimental Biology (DC)
Year: 2024 Accepted: 2025-07-11
Auditor: Gelman Rosenberg & Freedman

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
571018 2024-001 Significant Deficiency - I
571019 2024-002 Significant Deficiency - P
571020 2024-001 Significant Deficiency - I
571021 2024-002 Significant Deficiency - P
571022 2024-001 Significant Deficiency - I
571023 2024-002 Significant Deficiency - P
571024 2024-001 Significant Deficiency - I
571025 2024-002 Significant Deficiency - P
571026 2024-001 Significant Deficiency - I
571027 2024-002 Significant Deficiency - P
571028 2024-001 Significant Deficiency - I
571029 2024-002 Significant Deficiency - P
571030 2024-001 Significant Deficiency - I
571031 2024-002 Significant Deficiency - P
571032 2024-001 Significant Deficiency - I
571033 2024-002 Significant Deficiency - P
571034 2024-001 Significant Deficiency - I
571035 2024-002 Significant Deficiency - P
571036 2024-001 Significant Deficiency - I
571037 2024-002 Significant Deficiency - P
571038 2024-001 Significant Deficiency - I
571039 2024-002 Significant Deficiency - P
571040 2024-001 Significant Deficiency - I
571041 2024-002 Significant Deficiency - P
571042 2024-001 Significant Deficiency - I
571043 2024-002 Significant Deficiency - P
571044 2024-001 Significant Deficiency - I
571045 2024-002 Significant Deficiency - P
571046 2024-001 Significant Deficiency - I
571047 2024-002 Significant Deficiency - P
571048 2024-001 Significant Deficiency - I
571049 2024-002 Significant Deficiency - P
571050 2024-001 Significant Deficiency - I
571051 2024-002 Significant Deficiency - P
571052 2024-001 Significant Deficiency - I
571053 2024-002 Significant Deficiency - P
571054 2024-001 Significant Deficiency - I
571055 2024-002 Significant Deficiency - P
571056 2024-001 Significant Deficiency - I
571057 2024-002 Significant Deficiency - P
571058 2024-001 Significant Deficiency - I
571059 2024-002 Significant Deficiency - P
571060 2024-001 Significant Deficiency - I
571061 2024-002 Significant Deficiency - P
571062 2024-001 Significant Deficiency - I
571063 2024-002 Significant Deficiency - P
571064 2024-001 Significant Deficiency - I
571065 2024-002 Significant Deficiency - P
571066 2024-001 Significant Deficiency - I
571067 2024-002 Significant Deficiency - P
571068 2024-001 Significant Deficiency - I
571069 2024-002 Significant Deficiency - P
571070 2024-001 Significant Deficiency - I
571071 2024-002 Significant Deficiency - P
571072 2024-001 Significant Deficiency - I
571073 2024-002 Significant Deficiency - P
571074 2024-001 Significant Deficiency - I
571075 2024-002 Significant Deficiency - P
571076 2024-001 Significant Deficiency - I
571077 2024-002 Significant Deficiency - P
571078 2024-001 Significant Deficiency - I
571079 2024-002 Significant Deficiency - P
571080 2024-001 Significant Deficiency - I
571081 2024-002 Significant Deficiency - P
571082 2024-001 Significant Deficiency - I
571083 2024-002 Significant Deficiency - P
571084 2024-001 Significant Deficiency - I
571085 2024-002 Significant Deficiency - P
571086 2024-001 Significant Deficiency - I
571087 2024-002 Significant Deficiency - P
571088 2024-001 Significant Deficiency - I
571089 2024-002 Significant Deficiency - P
571090 2024-001 Significant Deficiency - I
571091 2024-002 Significant Deficiency - P
571092 2024-001 Significant Deficiency - I
571093 2024-002 Significant Deficiency - P
571094 2024-001 Significant Deficiency - I
571095 2024-002 Significant Deficiency - P
571096 2024-001 Significant Deficiency - I
571097 2024-002 Significant Deficiency - P
571098 2024-001 Significant Deficiency - I
571099 2024-002 Significant Deficiency - P
571100 2024-001 Significant Deficiency - I
571101 2024-002 Significant Deficiency - P
571102 2024-001 Significant Deficiency - I
571103 2024-002 Significant Deficiency - P
571104 2024-001 Significant Deficiency - I
571105 2024-002 Significant Deficiency - P
1147460 2024-001 Significant Deficiency - I
1147461 2024-002 Significant Deficiency - P
1147462 2024-001 Significant Deficiency - I
1147463 2024-002 Significant Deficiency - P
1147464 2024-001 Significant Deficiency - I
1147465 2024-002 Significant Deficiency - P
1147466 2024-001 Significant Deficiency - I
1147467 2024-002 Significant Deficiency - P
1147468 2024-001 Significant Deficiency - I
1147469 2024-002 Significant Deficiency - P
1147470 2024-001 Significant Deficiency - I
1147471 2024-002 Significant Deficiency - P
1147472 2024-001 Significant Deficiency - I
1147473 2024-002 Significant Deficiency - P
1147474 2024-001 Significant Deficiency - I
1147475 2024-002 Significant Deficiency - P
1147476 2024-001 Significant Deficiency - I
1147477 2024-002 Significant Deficiency - P
1147478 2024-001 Significant Deficiency - I
1147479 2024-002 Significant Deficiency - P
1147480 2024-001 Significant Deficiency - I
1147481 2024-002 Significant Deficiency - P
1147482 2024-001 Significant Deficiency - I
1147483 2024-002 Significant Deficiency - P
1147484 2024-001 Significant Deficiency - I
1147485 2024-002 Significant Deficiency - P
1147486 2024-001 Significant Deficiency - I
1147487 2024-002 Significant Deficiency - P
1147488 2024-001 Significant Deficiency - I
1147489 2024-002 Significant Deficiency - P
1147490 2024-001 Significant Deficiency - I
1147491 2024-002 Significant Deficiency - P
1147492 2024-001 Significant Deficiency - I
1147493 2024-002 Significant Deficiency - P
1147494 2024-001 Significant Deficiency - I
1147495 2024-002 Significant Deficiency - P
1147496 2024-001 Significant Deficiency - I
1147497 2024-002 Significant Deficiency - P
1147498 2024-001 Significant Deficiency - I
1147499 2024-002 Significant Deficiency - P
1147500 2024-001 Significant Deficiency - I
1147501 2024-002 Significant Deficiency - P
1147502 2024-001 Significant Deficiency - I
1147503 2024-002 Significant Deficiency - P
1147504 2024-001 Significant Deficiency - I
1147505 2024-002 Significant Deficiency - P
1147506 2024-001 Significant Deficiency - I
1147507 2024-002 Significant Deficiency - P
1147508 2024-001 Significant Deficiency - I
1147509 2024-002 Significant Deficiency - P
1147510 2024-001 Significant Deficiency - I
1147511 2024-002 Significant Deficiency - P
1147512 2024-001 Significant Deficiency - I
1147513 2024-002 Significant Deficiency - P
1147514 2024-001 Significant Deficiency - I
1147515 2024-002 Significant Deficiency - P
1147516 2024-001 Significant Deficiency - I
1147517 2024-002 Significant Deficiency - P
1147518 2024-001 Significant Deficiency - I
1147519 2024-002 Significant Deficiency - P
1147520 2024-001 Significant Deficiency - I
1147521 2024-002 Significant Deficiency - P
1147522 2024-001 Significant Deficiency - I
1147523 2024-002 Significant Deficiency - P
1147524 2024-001 Significant Deficiency - I
1147525 2024-002 Significant Deficiency - P
1147526 2024-001 Significant Deficiency - I
1147527 2024-002 Significant Deficiency - P
1147528 2024-001 Significant Deficiency - I
1147529 2024-002 Significant Deficiency - P
1147530 2024-001 Significant Deficiency - I
1147531 2024-002 Significant Deficiency - P
1147532 2024-001 Significant Deficiency - I
1147533 2024-002 Significant Deficiency - P
1147534 2024-001 Significant Deficiency - I
1147535 2024-002 Significant Deficiency - P
1147536 2024-001 Significant Deficiency - I
1147537 2024-002 Significant Deficiency - P
1147538 2024-001 Significant Deficiency - I
1147539 2024-002 Significant Deficiency - P
1147540 2024-001 Significant Deficiency - I
1147541 2024-002 Significant Deficiency - P
1147542 2024-001 Significant Deficiency - I
1147543 2024-002 Significant Deficiency - P
1147544 2024-001 Significant Deficiency - I
1147545 2024-002 Significant Deficiency - P
1147546 2024-001 Significant Deficiency - I
1147547 2024-002 Significant Deficiency - P

Programs

ALN Program Spent Major Findings
93.859 Biomedical Research and Research Training $201,724 Yes 2
10.025 Plant and Animal Disease, Pest Control, and Animal Care $155,875 - 0
93.310 Trans-Nih Research Support $72,333 Yes 2
93.867 Vision Research $58,403 Yes 2
10.310 Agriculture and Food Research Initiative (afri) $40,580 - 0
93.838 Lung Diseases Research $32,896 Yes 2
93.866 Aging Research $28,500 Yes 2
93.865 Child Health and Human Development Extramural Research $26,659 Yes 2
93.855 Allergy and Infectious Diseases Research $20,947 Yes 2
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $17,600 Yes 2
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $16,739 Yes 2
93.837 Cardiovascular Diseases Research $13,300 Yes 2
93.398 Cancer Research Manpower $6,996 Yes 2
47.074 Biological Sciences $5,843 Yes 2
93.396 Cancer Biology Research $4,000 Yes 2
93.113 Environmental Health $750 Yes 2

Contacts

Name Title Type
CLHCSTHHSX25 Frank Krause Auditee
3016347286 John McIntosh Auditor
No contacts on file

Notes to SEFA

Title: Note 1. Basis of Presentation Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. De Minimis Rate Used: Y Rate Explanation: Such expenditures are recognized following the cost principles contained in Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. FASEB has elected to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the Federal grant activity of FASEB under programs of the Federal Government for the year ended December 31, 2024. The information in the Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The Schedule presents only a selected portion of the operations of FASEB; accordingly, it is not intended to and does not present the consolidated financial position, changes in net assets or cash flows of FASEB.
Title: Note 2. Summary of Significant Accounting Policies Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. De Minimis Rate Used: Y Rate Explanation: Such expenditures are recognized following the cost principles contained in Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. FASEB has elected to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. FASEB has elected to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance.

Finding Details

Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.
Finding 2024-001
Finding 2024-001 Procurement and Suspension and Debarment (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): § 200.318 (i) General procurement standards, states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Furthermore: §200.320 (f) Methods of procurement to be followed, states that procurement by noncompetitive proposals is procurement through solicitation of a proposal from only one source and may be used only when certain requirements have been met. Additionally, §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award states that non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The non-Federal entity must verify that the person with whom you intend to do business is not excluded or disqualified, by (a) checking SAM Exclusions; (b) collecting a certification from that person; (c) adding a clause or condition to the covered transaction with that person. Condition: During our audit, we noted that while FASEB has formal procurement policies under §200.318(i) and §200.320(f), it did not provide sufficient records detailing the procurement history or justification for noncompetitive selections in our sample. Additionally, FASEB lacks formal policies on suspension and debarment, and SAM exclusion screening documentation was not provided for the sampled contracts and vendors. Cause: FASEB’s procedures did not provide for the formalization and retention of procurement records and vendor screenings consistent with the expectations outlined in 2 CFR 200. Effect or Potential Effect: Purchases of goods and services could be made above the prevailing market rates if the prescribed procurement procedures are not adhered to. Finally, FASEB could inadvertently enter into a contractual relationship with an entity that is suspended, debarred or otherwise included on the US Federal sanction list. Questioned Costs: N/A. Context: Our audit work in this area consisted of internal control testwork over a random sample of expenditures. We consider our samples to be representative of the respective populations, and thus, are statistically valid samples. Identification as a Repeat Finding, if Applicable: N/A Recommendation: We then recommend that FASEB develop and adhere to formal policies (as applicable) related to § 200.318 (i) General procurement standards, §200.320 (f) Methods of procurement to be followed, as well as §200.213 Reporting a determination that a non-Federal entity is not qualified for a Federal award. All procurement actions and SAM exclusion screenings should be clearly documented in writing and maintained in the vendor or contractor files.
Finding 2024-002
Finding 2024-002 Schedule of Expenditures of Federal Awards (SEFA) Preparation (Significant Deficiency) Information on the Federal Programs: Research and Development Cluster. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Per 2 CFR § 200.510(b), the auditee must prepare a SEFA for the period covered by the auditee’s financial statements. The SEFA must include total Federal awards expended, including Federal awards passed through from other entities, the name of the pass-through entity, and the identifying number assigned by the pass-through entity. Condition: During audit procedures, we identified a Federal pass-through award from under the Research and Development Cluster that was omitted from the preliminary SEFA. The expenditures associated with this award totaled approximately $72,000 for the fiscal year ended December 31, 2024. Cause: The omission resulted from inadequate internal controls over the collection and review of information used to prepare the SEFA. The client relied on a manual process to track Federal awards, and the pass-through award was not included in the final SEFA due to oversight. Effect or Potential Effect: The SEFA provided to auditors was incomplete and did not accurately represent the total Federal expenditures. This could lead to an understatement of total Federal expenditures and result in noncompliance with Uniform Guidance reporting requirements. Questioned Costs: N/A. Context: The SEFA initially provided by FASEB included 45 Federal awards with total expenditures of $1,248,060. The omitted pass-through award represented expenditures of $72,333, or approximately 6% of total Federal expenditures for the year. The omission appears to be isolated to this particular award; however, it was not detected by FASEB’s existing SEFA preparation and review process. Identification as a Repeat Finding, if Applicable: N/A. Recommendation: We recommend FASEB enhance its internal control procedures over SEFA preparation to ensure all Federal awards, including those received through pass-through entities, are properly identified, tracked, and reported. This could include periodic reconciliations between the general ledger and award documentation and a formal review process prior to finalizing the SEFA.